Legal Opinion

American Ry. Co. v. Commissioner

United States Board of Tax Appeals

Decided June 19, 1934No. Docket No. 67662Published

1. A consent in writing extending the statutory period for assessment of taxes executed by the taxpayer and transmitted to the Commissioner, which was not signed or relied upon or acted upon by the latter, but was definitely rejected by him as unacceptable, and under which the taxpayer neither received nor accepted any benefits, is invalid; and the fact that the signature of the Commissioner was placed thereon several years after the expiration of the statutory period for…

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1. A consent in writing extending the statutory period for assessment of taxes executed by the taxpayer and transmitted to the Commissioner, which was not signed or relied upon or acted upon by the latter, but was definitely rejected by him as unacceptable, and under which the taxpayer neither received nor accepted any benefits, is invalid; and the fact that the signature of the Commissioner was placed thereon several years after the expiration of the statutory period for assessment - in this case on the day of the trial before the Board - can have no effect whatever upon the statute of…

1Opinion of the Court

THE AMERICAN RAILWAYS COMPANY, FORMERLY AMERICAN ELECTRIC POWER COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

American Ry. Co. v. Commissioner

Docket No. 67662.

United States Board of Tax Appeals

30 B.T.A. 939; 1934 BTA LEXIS 1240;

June 19, 1934, Promulgated

1. A consent in writing extending the statutory period for assessment of taxes executed by the taxpayer and transmitted to the Commissioner, which was not signed or relied upon or acted upon by the latter, but was definitely rejected by him as unacceptable, and under which the taxpayer neither received nor accepted any…

2Cases cited1 opinion

  1. American Ry. Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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