Miami Metals Co. v. Commissioner
United States Board of Tax Appeals
JURISDICTION. - On March 7, and July 28, 1925, the respondent notified the petitioner by registered mail that the latter's abatement claim filed on March 6, 1924, was rejected. Thereafter, however, the respondent reconsidered his determination of the petitioner's tax liability for the year covered by the claim and on November 20, 1925, he again notified the petitioner by registered mail that the conclusions set forth in the letter of March 7, 1925, were sustained.
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JURISDICTION. - On March 7, and July 28, 1925, the respondent notified the petitioner by registered mail that the latter's abatement claim filed on March 6, 1924, was rejected. Thereafter, however, the respondent reconsidered his determination of the petitioner's tax liability for the year covered by the claim and on November 20, 1925, he again notified the petitioner by registered mail that the conclusions set forth in the letter of March 7, 1925, were sustained. On January 18, 1926, the petitioner filed its petition for redetermination with the board. Held, the Board has jurisdiction, under…
1Opinion of the Court
*425OPINION.
Geeen:
Section 288(f) of the Revenue Act of 1926 provides that:
If any deficiency in any income, war-profits or excess-profits tax imposed by the Revenue Act of 1916, the Revenue Act of 1917, the Revenue Act of 1918, or the Revenue Act of 1921, or by any such Act as amended, was assessed before June 3, 1924, but was not paid in full before that date, and if the Commissioner after June 2, 1924, but before the enactment of this Act finally determined the amount of the deficiency, and if the person liable for such tax appealed before the enactment of this Act to the Board and the appeal is…
2Cited by1 opinion
- Miami Metals Co. v. CommissionerUnited States Board of Tax Appeals · 1928