John D. Borgman 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.

• the section 6212(b)(1) safe harbor renders an unreceived notice valid if the IRS mailed it to the taxpayer's last known address
• “The purpose of section[] 6212(a) . . . is to ensure that the taxpayer receives a timely actual notice so he can challenge the assessment within the 90-day period provided in section 6213.”

Source: CourtListener parenthetical corpus (CC0).