Jerry W. And Jeanette Mulder 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.

• finding no “due diligence” where “two letters posted shortly before the notice ... were returned undelivered” and the notice itself was neither delivered nor returned
• listing different actions taken in other cases that might constitute reasonable diligence
• “[T]he taxpayer must file a petition within 90 days of this mailing [of the notice of deficiency]. Otherwise, the Tax Court lacks jurisdiction”
• “While it is presumed that a properly-addressed piece of mail placed in the care of the Postal Service has been delivered, no such presumption of delivery exists for certified mail when the requested return receipt is not received by the sender.”

Source: CourtListener parenthetical corpus (CC0).