344 CORP v. KIPLING CAPITAL, L P

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that “[i]f the notice of deficiency is found to be invalid, we must dismiss in petitioner’s favor regardless of whether the taxpayer’s petition was timely filed.”
• “There are two prerequisites to this Court’s jurisdiction to redetermine a deficiency: (1) The issuance of a valid notice of deficiency by the Commissioner; and (2) the timely filing of a petition with, the Court by the taxpayer.”

Source: CourtListener parenthetical corpus (CC0).