Legal Opinion

Greve v. Commissioner

United States Board of Tax Appeals

Decided June 19, 1940No. Docket No. 97522Published

STATUTE OF LIMITATION - SUSPENSION. - The running of the period of limitation upon assessment and collection is not suspended under section 277 of the Revenue Act of 1928 by the sending of a notice which is not a proper notice under section 272(a). There can be no suspension of the running after the period has completely run.

1Opinion of the Court

WILLIAM M. GREVE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Greve v. Commissioner

Docket No. 97522.

United States Board of Tax Appeals

42 B.T.A. 142; 1940 BTA LEXIS 1042;

June 19, 1940 Promulgated

STATUTE OF LIMITATION - SUSPENSION. - The running of the period of limitation upon assessment and collection is not suspended under section 277 of the Revenue Act of 1928 by the sending of a notice which is not a proper notice under section 272(a). There can be no suspension of the running after the period has completely run.

Lawrence A. Baker, Esq., for the petitioner.

James R. Johnston,…

2Cases cited1 opinion

  1. Greve v. CommissionerUnited States Board of Tax Appeals · 1940

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