Robert T. Frost a/k/a Robert Frost v. Christiana Trust, a Division of Wilmington Savings Fund Society, FSB, etc.

How courts have described this case

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

• holding that proof of mailing was \otherwise sufficient\ where IRS produced copies of the deficiency notices, the defects in the USPS Forms 3877 were minor, and the Forms 3877 were datestamped with the date on which the notices were submitted to USPS
• observing that a combination of proof of the existence of a deficiency notice and an incomplete Form 3877 with relevant mailing information may be sufficient to meet the Commissioner’s burden
• explaining that once the IRS has satisfied its burden of showing that deficiency notices existed and were mailed to the taxpayer, the burden shifts to the taxpayer who must rebut with clear and convincing evidence
• explaining that once the IRS has satisfied its burden of showing that deficiency notices existed and were mailed to the taxpayer, the burden shifts to the taxpayer who must rebut with clear and convincing evidence
• stating proof that notice of deficiency exists is established by providing a copy of the notice
• indicating that these criteria, if met, will establish the presumption

Source: CourtListener parenthetical corpus (CC0).