Turner v. Comm'r of Revenue
Annotate this CaseAfter completing an audit of Taxpayers' joint income tax returns, the Commissioner of Revenue issued an order assessing additional taxes. That day, a revenue tax specialist sent Taxpayers an e-mail informing them of the existence of the order. The order was attached to the e-mail. Taxpayers claimed to have been unable to open the attachment containing the letter until sixty-six days after receiving the e-mail. The specialist claimed that he also sent the order by regular mail to Taxpayers' home address, but Taxpayers contended that a mailed copy of the order never arrived. Fifty-three days after Taxpayers opened the e-mail attachment and 119 days after they received the e-mail, Taxpayers filed an appeal with the tax court. The tax court dismissed the appeal as untimely, as it was filed after the sixty-day statutory deadline. The Supreme Court affirmed, holding (1) the tax court's findings that sending the order to Taxpayers electronically and by regular mail was sufficient were not clearly erroneous; and (2) the methods by which the Commissioner sent the order did not violate Taxpayers' due process rights.
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