Opinion

Rosenheim v. Commissioner

  • 45 B.T.A. 1018
  • 1941 BTA LEXIS 1034
Court
United States Board of Tax Appeals
Filed
Dec 17, 1941
Status
Published
Author
Murdock
On the bench
Harron, Sternhagen, Smith, Arnold, Agree, Keen, Mellott, Arundell, Murdock
Cited by
5 cases

The opinion

Murdock,

concurring: The Commissioner does not contend that the first notice was sent to the “last known address” of the taxpayer. His point, as explained in the majority opinion, is that receipt of the notice by the taxpayer is sufficient. The taxpayer, under the circumstances of this case, was under no burden to show that the address to which the notice was sent was not the address last known to the Commissioner. The Commissioner makes no contention that it was the last known address. He refers to it merely as a “former address.” For these reasons I think the majority opinion is correct.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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