Henry G. Pugsley v. Commissioner of Internal Revenue, Joseph T. Rezzonico 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.

• time begins to run on date of mailing if ample time to file a petition
• “[T]imely filing of * * * a petition is a jurisdictional prerequisite for a suit in the tax court.”
• “[T]imely filing of such a petition is a jurisdictional prerequisite for a suit in the tax court”
• even though notice of deficiency was not sent to last known address, taxpayer was not prejudiced because he received actual notice of deficiency in ample time to petition this Court
• “It is apparent from the numerous references to ‘United States mail’ in the statutes and regulations that section 7502 is intended to apply only to mail delivered by the United States Postal Service and not also to items delivered by a private delivery system.”
• \It is apparent from the numerous references to 'United States mail’ in the statutes and regulations that section 7502 is intended to apply only to mail delivered by the United States Postal Service and not also to items delivered by a private delivery system.\

Source: CourtListener parenthetical corpus (CC0).