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Underwriters, Inc. v. Commissioner of Internal Revenue, 215 F.2d 953, 3rd Cir. (1954)
Underwriters, Inc. v. Commissioner of Internal Revenue, 215 F.2d 953, 3rd Cir. (1954)
2d 953
54-2 USTC P 9611
The petitioner seeks to review an order of the Tax Court dismissing its petition
for lack of jurisdiction. It appears that the notice of deficiency was mailed on
December 12, 1952 and that the petition was filed with the Tax Court on March
13, 1953, which was 91 days thereafter. It was, therefore, filed out of time and
conferred no jurisdiction on the court. The order of the Tax Court will
accordingly be affirmed.