Adler v. Commissioner
United States Tax Court
Upon the facts, held: 1. The errors in Ps' return did not constitute "mathematical or clerical errors appearing on the return" within the meaning of sec. 6213(f)(2), I.R.C. 1954, of the Code. 2. The errors in Ps' return were of a type encompassed within a limited extension of the statute of limitations granted by Ps, and R's notice of deficiency was therefore timely.
1Opinion of the Court
OPINION
Kórner, Judge:
Respondent determined a deficiency in petitioners’ income tax for the calendar year 1978 in the amount of $25,765. After agreement by the parties on an unrelated matter,1 the sole issue which we must determine is whether respondent’s statutory notice of deficiency for 1978 was issued after the expiration of the effective statute of limitations under section 6501.2
The case was submitted to the Court on a fully stipulated set of facts and exhibits pursuant to the provisions of Rule 122, and our findings of fact herein are based upon such stipulated facts and documents.
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2Cases cited2 opinions
- Concrete Engineering Co. v. Commissioner of Int. Rev.Court of Appeals for the Eighth Circuit · 1932
- Stern Bros. & Co. v. BurnetCourt of Appeals for the Eighth Circuit · 1931
3Cited by110 opinions
- Woods v. CommissionerUnited States Tax Court · 1989
- Kronish v. CommissionerUnited States Tax Court · 1988
- Coleman v. CommissionerUnited States Tax Court · 1990
- Donald Feldman and Patricia Feldman, A/K/A Patsy Jane Feldman v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1994
- Amesbury Apartments, Ltd. v. CommissionerUnited States Tax Court · 1990
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