U.S. Court of Appeals for the Third Circuit, 1954

Underwriters, Inc. v. Commissioner of Internal Revenue

U.S. Court of Appeals for the Third Circuit · Decided October 13, 1954 · Maris, McLAUGHLIN, Per Curiam, Staley

215 F.2d 953; 46 A.F.T.R. (P-H) 623; 1954 U.S. App. LEXIS 4360 (Federal Reporter, Second Series)

Counsel

J. Webster Jones, Philadelphia, Pa., for petitioner., H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Hilbert P. Zarky, C. Guy Tadlock, Sp. Assts. to the Atty. Gen., on the brief for respondent.

Cases that cite this one

6 later published cases cite this decision.

Hallmark Research Collective (United States Tax Court 2022)
Heaberlin v. Commissioner (United States Tax Court 1960)
Albert G. Rich v. Commissioner of Internal Revenue (5th Cir. 1957)
Estate of Krueger v. Commissioner (United States Tax Court 1960)
Theron C. Teel and Lynn W. Teel v. Commissioner of Internal Revenue (10th Cir. 1957)
Borden Co. v. United States (District Court, D. New Jersey 1955)

This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.

Opinion

PER CURIAM.

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.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.