Nnabugwu Eze v. Commissioner of Internal Revenue

Whether the Court erred in not dismissing the case for lack of jurisdiction on the ground that no notice of deficiency was issued to petitioner within 90 days of the date of the tax court petition, and no notice of determination was issued to petitioner within 30 days of the date of the tax court petition that would permit petitioner to invoke the Tax Court’s jurisdiction, as mandated by 26 U.S.C. § 6213(a), invalidating the notice of deficiency for tax years 2015 and 2016 and affecting the Court’s jurisdiction.

Whether the court failed to apply the Cohen rule appropriately concerning the estimation of business expenses when exact substantiation is unavailable, thereby