# Rosenheim v. Commissioner

> United States Board of Tax Appeals · December 17, 1941 · 45 B.T.A. 1018

URL: https://www.frixlaw.com/law-library/cases/4498682

## Case

- **Full name:** CAROLINE ROSENHEIM, <emphasis typestyle="it">v.</emphasis> COMMISSIONER OF INTERNAL REVENUE
- **Court:** United States Board of Tax Appeals
- **Decided:** December 17, 1941
- **Citations:** 45 B.T.A. 1018; 1941 BTA LEXIS 1034
- **Precedential status:** Published
- **Opinion:** Concurrence by Murdock
- **Judges:** Harron, Sternhagen, Smith, Arnold, Agree, Keen, Mellott, Arundell, Murdock
- **Cited by:** 5 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/4498682

## Opinion text

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.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4498682. Public record. Not legal advice.
