Underwriters, Inc. v. Commissioner of Internal Revenue
This text of 215 F.2d 953 (Underwriters, Inc. v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
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.
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Cite This Page — Counsel Stack
215 F.2d 953, 46 A.F.T.R. (P-H) 623, 1954 U.S. App. LEXIS 4360, Counsel Stack Legal Research, https://law.counselstack.com/opinion/underwriters-inc-v-commissioner-of-internal-revenue-ca3-1954.