Legal Opinion
Commissioner of Internal Revenue v. Stewart
Court of Appeals for the Sixth Circuit
Decided January 23, 1951No. 11154PublishedCited by 89 opinions
1Opinion of the Court
MILLER, Circuit Judge.
The Commissioner of Internal Revenue seeks a review of the ruling of the Tax Court which held that a notice of deficiency was invalid for failure to comply with the statutory provisions with respect to mailing.
The notice of deficiency was in the usual form; its inside address was to “Dr. Kirk Stewart, 904 Stroh Bldg., Detroit, Mich.,” the taxpayer and respondent herein; it was dated March 10, 1948; it was enclosed in an envelope addressed to the taxpayer’s counsel, Mel W. Werden, 7310 Woodward Avenue, Detroit, Michigan. It was sent by registered mail. The letter stated—
“Y…
2Cases cited15 opinions
- Olsen v. HelveringCourt of Appeals for the Second Circuit · 1937
- Commissioner of Internal Revenue v. Forest Glen C. Co.Court of Appeals for the Seventh Circuit · 1938
- Ventura Consolidated Oil Fields v. RoganCourt of Appeals for the Ninth Circuit · 1936
- Commissioner of Internal Revenue v. New York Trust Co.Court of Appeals for the Second Circuit · 1931
- Burnet v. San Joaquin Fruit & Investment Co.Court of Appeals for the Ninth Circuit · 1931
10 more not listed; retrieve them via the Exa API.
3Cited by89 opinions
- Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Frieling v. CommissionerUnited States Tax Court · 1983
- Foster v. Comm'rUnited States Tax Court · 1983
- United States v. Edward J. AhrensCourt of Appeals for the Eighth Circuit · 1976
84 more not listed; retrieve them via the Exa API.