Taylor v. Commissioner
United States Board of Tax Appeals
JURISDICTION. - Petitioner personally did not file an income tax return for the year 1917, but on February 5, 1935, respondent prepared and filed such return for petitioner, pursuant to section 3176 of the Revised Statutes as amended.
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JURISDICTION. - Petitioner personally did not file an income tax return for the year 1917, but on February 5, 1935, respondent prepared and filed such return for petitioner, pursuant to section 3176 of the Revised Statutes as amended. On February 8, 1935, respondent mailed a notice to petitioner, in the usual form, advising him of the determination of a deficiency and penalty in the same amounts as shown in the return filed by respondent for petitioner, from which notice petitioner timely appealed to the Board. Held, in such case the amount admitted to be due and not the amount shown on the…
1Opinion of the Court
OPINION.
Hill:
On April 26, 1937, respondent filed a motion to dismiss this proceeding for lack of jurisdiction, on the ground that the notice mailed to petitioner on February 8, 1935, which purports to be a notice of deficiency in accordance with section 274 (a) of the Revenue Act of 1926, as amended by section 501 of the Revenue Act of 1934, and section 283 of the Revenue Act of 1926, from which notice the appeal herein was taken, is not such a notice as is provided for by the statute, “in that the tax liability and additions thereto inputed in such notice are not in excess of the amount of…
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- Millsap v. CommissionerUnited States Tax Court · 1988
- Kearney v. A'HearnDistrict Court, S.D. New York · 1962
- Russell v. United StatesDistrict Court, W.D. Missouri · 1991
- Berwindmoor S.S. Co. v. CommissionerUnited States Tax Court · 1944
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