Wright v. Commissioner of Internal Revenue

Fourth Circuit

Wright v. Commissioner of Internal Revenue

101 F.2d 309, 22 A.F.T.R. (P-H) 442, 1939 U.S. App. LEXIS 4374

CourtCourt of Appeals for the Fourth Circuit

DecidedJanuary 18, 1939

Docket4415

StatusPublished

Cited by4 cases

This text of 101 F.2d 309 (Wright v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Wright v. Commissioner of Internal Revenue, 101 F.2d 309, 22 A.F.T.R. (P-H) 442, 1939 U.S. App. LEXIS 4374 (4th Cir. 1939).

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Opinion

PER CURIAM.

This is a petition to review a decision of the Board of Tax Appeals. The only question involved is whether a deficiency notice mailed by the Commissioner of Internal Revenue to the taxpayer was sufficient to toll the running of the statute of limitations. The address of the taxpayer given on his tax return was 917 15th Street N. W., Washington, D. C. The deficiency notice was addressed to him at 915 15th Street, N. W., Washington, D. G, and was sent by registered mail. It was delivered at his office to an employee authorized to receive and open his mail. The objection made is that the address on the deficiency notice did not correspond with that on the tax return; hut it is undisputed that the notice was delivered at taxpayer’s office and we think that the receipt by the employee under the circumstances shown was equivalent to receipt by taxpayer himself. The slight error in the street address did no harm; and we agree with the Board that “the contention made is devoid of any merit”.

Affirmed.

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PER CURIAM.

This is a petition to review a decision of the Board of Tax Appeals. The only question involved is whether a deficiency notice mailed by the Commissioner of Internal Revenue to the taxpayer was sufficient to toll the running of the statute of limitations. The address of the taxpayer given on his tax return was 917 15th Street N. W., Washington, D. C. The deficiency notice was addressed to him at 915 15th Street, N. W., Washington, D. G, and was sent by registered mail. It was delivered at his office to an employee authorized to receive and open his mail. The objection made is that the address on the deficiency notice did not correspond with that on the tax return; hut it is undisputed that the notice was delivered at taxpayer’s office and we think that the receipt by the employee under the circumstances shown was equivalent to receipt by taxpayer himself. The slight error in the street address did no harm; and we agree with the Board that “the contention made is devoid of any merit”.

Affirmed.

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101 F.2d 309, 22 A.F.T.R. (P-H) 442, 1939 U.S. App. LEXIS 4374, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wright-v-commissioner-of-internal-revenue-ca4-1939.

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