Legal Opinion
United States v. Price
Supreme Court of the United States
Decided January 18, 1960No. 48PublishedCited by 544 opinions
1Opinion of the CourtJustice Harlan
The United States brought, this action against the respondent taxpayer for the collection of a deficiency in taxes for the year 1946, and statutory interest thereon. The respondent defended on the ground that the action could not be maintained because. the Commissioner of Internal Revenue had never issued to the taxpayer a notice of deficiency (commonly known as a “90-day letter”) for the amount in question. This defense was based on § 272 (a)(1) of the Internal Revenue Code of 1939, 53 *305Stat. 82, as amended, providing in pertinent part as follows:
“If in the case of any taxpayer, the…
2Cases cited8 opinions
- United States v. United Mine Workers of AmericaSupreme Court of the United States · 1947
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- McCarthy Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1935
- Moore v. Cleveland Ry. Co.Court of Appeals for the Sixth Circuit · 1940
- Mutual Lumber Co. v. PoeCourt of Appeals for the Ninth Circuit · 1933
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3Cited by544 opinions
- Firestone Tire & Rubber Co. v. BruchSupreme Court of the United States · 1989
- Russello v. United StatesSupreme Court of the United States · 1983
- Cipollone v. Liggett Group, Inc.Supreme Court of the United States · 1992
- Jones v. United StatesSupreme Court of the United States · 1999
- Massachusetts v. Environmental Protection AgencySupreme Court of the United States · 2007
539 more not listed; retrieve them via the Exa API.