Underwriters, Inc. v. Commissioner of Internal Revenue
U.S. Court of Appeals for the Third Circuit
Underwriters, Inc. v. Commissioner of Internal Revenue, 215 F.2d 953 (3d Cir. 1954)
46 A.F.T.R. (P-H) 623; 1954 U.S. App. LEXIS 4360
Underwriters, Inc. v. Commissioner of Internal Revenue
Opinion
The petitioner seeks to review an order of the Tax Court dismissing its petition for lack of jurisdiction. It appears that the notice of deficiency was mailed on December 12, 1952 and that the petition was filed with the Tax Court on March 13, 1953, which was 91 days thereafter. It was, therefore, filed out of time and conferred no jurisdiction on the court. The order of the Tax Court will accordingly be affirmed.
Reference
- Full Case Name
- UNDERWRITERS, Inc., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
- Cited By
- 8 cases
- Status
- Published