Gerald D. Ward and Joan Ward (Deceased) v. Commissioner of Internal Revenue

How courts have described this case

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

• holding that no valid notice of deficiency was mailed because the notice was not mailed to the taxpayer's last known address, but noting that the \waiver of a limitations period under Form 872-A does not terminate until after the IRS sends a valid notice of deficiency\
• “[W]hen the IRS was aware before mailing the deficiency notice that the taxpayer had moved, the IRS was required to exercise greater diligence .... ”
• \The waiver of a limitations period under Form 872-A does not terminate until after the IRS sends a valid notice of deficiency to the taxpayer.\
• not abuse of discretion for Tax Court to set aside default judgment under Tax Ct. R. 123
• “In order for the Tax Court to have jurisdiction over a petition for redetermination, the taxpayer must file the petition within 90 days after ‘the notice of deficiency authorized in § 6212 is mailed.’ 26 U.S.C. § 6213”
• most recent tax return filed

Source: CourtListener parenthetical corpus (CC0).