Legal Opinion

F. A. Hall Co. v. Commissioner

United States Board of Tax Appeals

Decided April 3, 1926No. Docket No. 4612PublishedCited by 13 opinions

STATUTE OF LIMITATIONS. - The consolidated income and profits-tax return for the year 1918, made on behalf of taxpayer and its associated company and containing the facts respecting gross income and allowable deductions required by section 239 of the Revenue Act of 1918, it appearing that said return was neither false nor fraudulent, was the return of each of said corporations required by the then existing law, and the statute of limitations, section 277(a)(2) of the Revenue…

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STATUTE OF LIMITATIONS. - The consolidated income and profits-tax return for the year 1918, made on behalf of taxpayer and its associated company and containing the facts respecting gross income and allowable deductions required by section 239 of the Revenue Act of 1918, it appearing that said return was neither false nor fraudulent, was the return of each of said corporations required by the then existing law, and the statute of limitations, section 277(a)(2) of the Revenue Act of 1924, began to run on April 14, 1919, the day following the day on which said return was filed with the…

1Opinion of the Court

*1175OPINION.

Tbussell: There is presented to us for consideration only the question of whether, on April 8, 1925, the Commissioner was barred by the statute of limitations from asserting and proposing to assess income and profits taxes against this taxpayer for the calendar year 1918, or for any part of that year. Section 277 (a) (2) of the Keve-nue Act of 1924 is the statute of limitations governing the issue here presented and reads as follows:

The amount of income, excess-profits, and war-profits taxes imposed by the Act entitled “An Act to provide revenue, equalize duties, and encourage the…

2Cited by13 opinions

  1. Houston v. CommissionerUnited States Tax Court · 1962
  2. General Mfg. Corp. v. CommissionerUnited States Tax Court · 1965
  3. Cem Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Cantrell & Cochrane v. CommissionerUnited States Board of Tax Appeals · 1930
  5. General Mfg. Corp. v. CommissionerUnited States Tax Court · 1965

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