# Estate of Wood v. Commissioner

> United States Tax Court · April 12, 1989 · 92 T.C. 793

URL: https://www.frixlaw.com/law-library/cases/4486297

## Case

- **Full name:** Estate of Leonard A. Wood, J.M. Loonan, Personal Representative v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** April 12, 1989
- **Citations:** 92 T.C. 793; 92 T.C. No. 46; 1989 U.S. Tax Ct. LEXIS 51
- **Precedential status:** Published
- **Opinion:** Concurrence by Cohen
- **Judges:** Williams,Chabot,Swift,Wright,Wells,Ruwe,Whalen,Colvin,Cohen,Hamblen,Jacobs,Parr,Ruwe,Whitaker,Nims,Korner,Gerber
- **Cited by:** 41 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4486297

## Opinion text

COHEN, J., concurring: I agree with the result in this case because of (1) the rare concurrence of events by which petitioner was able to prove to the satisfaction of the trial judge the date of the postmark without physical evidence, and (2) respondent’s failure to present evidence that the return was not delivered.
Hamblen, Jacobs, Parr, and Ruwe, JJ., agree with this concurring opinion.

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4486297. Public record. Not legal advice.