SANDERLING, INC. v. C. I. R.

No. 77-1599.

571 F.2d 174 (1978)

SANDERLING, INC., Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Third Circuit.

Decided February 21, 1978.


Attorney(s) appearing for the Case

Herbert M. Gannet, David A. Miller, Newark, N. J., for appellant.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Richard W. Perkins, Anthony Ilardi, Jr., Tax Div. Dept. of Justice, Washington, D. C., for appellee.

Before ADAMS and WEIS, Circuit Judges and COOLAHAN, District Judge.


OPINION OF THE COURT

WEIS, Circuit Judge.

Whether waivers of the statute of limitations and an IRS statutory notice of deficiency were in themselves deficient is the question presented in this appeal from a redetermination by the Tax Court. We conclude taxpayer's challenge to the statutory notice must fail. However, we do agree with the taxpayer that no penalty for late filing should be imposed because responsibility for properly preparing and filing a return...

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