United States Fourth Circuit
ST. JOSEPH LEASE CAPITAL CORP. v. COMM'R OF INTERNAL REVENUE, 99-2473
A misaddressed notice of deficiency sent to the taxpayer suspended the running of the three-year limitations period, pursuant to 26 USC 6503(a)(1), because the taxpayer received actual notice in time to file a petition for reconsideration of the deficiency.
Appellate Information
- Decided 12/20/2000
- Published 12/20/2000
Judges
- Before NIEMEYER and MICHAEL, Circuit Judges, and STAMP, Chief United States District Judge for the Northern District of West Virginia, sitting by designation.
Court
- United States Fourth Circuit
Counsel
- For Appellees:
- COUNSEL: Henry G. Zapruder, Baker & Hostetler, L.L.P., Washington, DC, for Appellant. Gilbert Steven Rothenberg, Tax Division, United States Department of Justice, Washington, DC, for Appellee. ON BRIEF: Paula M. Junghans, Acting Assistant Attorney General, Ellen Page DelSole, Tax Division, United States Department of Justice, Washington, DC, for Appellee.