Legal Opinion

American Bond & Mortg. Co. v. Commissioner

United States Board of Tax Appeals

Decided February 8, 1929No. Docket No. 11799Published

1. JURISDICTION. - For the calendar year 1920, the Commissioner determined an overassessment, which represented the difference between the amount of tax shown on the original return and the amount of the tax liability as determined by the Commissioner for said year. The Board has no jurisdiction to redetermine the tax liability for 1920 and for that year the appeal is dismissed.

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1. JURISDICTION. - For the calendar year 1920, the Commissioner determined an overassessment, which represented the difference between the amount of tax shown on the original return and the amount of the tax liability as determined by the Commissioner for said year. The Board has no jurisdiction to redetermine the tax liability for 1920 and for that year the appeal is dismissed. See Revenue Act of 1926, section 274(g); Cornelius Cotton Mills,4 B.T.A. 255. 2. CONSOLIDATED INVESTED CAPITAL. - In the absence of evidence to show that the determination of the respondent is erroneous in amount, we…

1Opinion of the Court

AMERICAN BOND & MORTGAGE CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

American Bond & Mortg. Co. v. Commissioner

Docket No. 11799.

United States Board of Tax Appeals

15 B.T.A. 264; 1929 BTA LEXIS 2882;

February 8, 1929, Promulgated

1. JURISDICTION. - For the calendar year 1920, the Commissioner determined an overassessment, which represented the difference between the amount of tax shown on the original return and the amount of the tax liability as determined by the Commissioner for said year. The Board has no jurisdiction to redetermine the tax liability for 1920 and for that…

2Cases cited2 opinions

  1. Cornelius Cotton Mills v. CommissionerUnited States Board of Tax Appeals · 1926
  2. American Bond & Mortg. Co. v. CommissionerUnited States Board of Tax Appeals · 1929

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