COMMISSIONER OF INTERNAL REVENUE v. STEWART

No. 11154.

186 F.2d 239 (1951)

COMMISSIONER OF INTERNAL REVENUE v. STEWART.

United States Court of Appeals Sixth Circuit.

January 23, 1951.


Attorney(s) appearing for the Case

Virginia H. Adams, Washington, D. C. (Theron Lamar Caudle, Ellis N. Slack, and Virginia H. Adams, Washington, D. C., on the brief), for petitioner.

Roy F. Andes, Detroit, Mich. (Roy F. Andes, Detroit, Mich., on the brief), for respondent.

Before MARTIN, McALLISTER and MILLER, Circuit Judges.


MILLER, Circuit Judge.

The Commissioner of Internal Revenue seeks a review of the ruling of the Tax Court which held that a notice of deficiency was invalid for failure to comply with the statutory provisions with respect to mailing.

The notice of deficiency was in the usual form; its inside address was to "Dr. Kirk Stewart, 904 Stroh Bldg., Detroit, Mich.," the taxpayer and respondent herein; it was dated March 10...

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