Sarkissian v. Commissioner
Cases that cite this one
1 later published case cites this decision.
- Matthew Eric Baham & Jennifer Michelle Baham v. Commissioner (United States Tax Court 2017)
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
MEMORANDUM **
Arthur Sarkissian appeals from the Tax Court’s order dismissing his action for lack of subject matter jurisdiction. We have jurisdiction under 26 U.S.C. § 7482(a)(1). We review for clear error the Tax Court’s factual findings, Williams v. Comm’r, 935 F.2d 1066, 1068 (9th Cir. 1991), and we affirm.
The Tax Court did not clearly err in finding that Sarkissian actually received the notice of deficiency. See Erhard v. Comm’r, 87 F.3d 273, 274 (9th Cir. 1996) (notice of deficiency is valid if “the taxpayer actually receives the notice, regardless of where the IRS mails the notice”); see also Sparkman v. Comm’r, 509 F.3d 1149, 1156 (9th Cir. 2007) (“[T]he Tax Court ... may disregard uncontradicted testimony by a taxpayer where it finds that testimony lacking in credibility.” (citation and internal quotation marks omitted)).
We reject Sarkissian’s arguments concerning due process and the IRS’s alleged intentional failure to send notices to Sark-issian’s tax preparer and attorney.
AFFIRMED.
This disposition is not appropriate for publication and is not precedent except as provided by 9th Cir. R. 36-3.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.