Baker v. Commissioner
United States Board of Tax Appeals
1. JURISDICTION. - Where a deficiency notice was mailed to a taxpayer more than two years before the executrix of her estate included her estate in an appeal which the transferee was making from a transferee notice of deficiency, the Board has no jurisdiction to hear the appeal of the executrix because it was filed long after the statutory period had expired. 2. TRANSFEREE LIABILITY. - Where prior to her death a mother transferred to her daughter without monetary…
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1. JURISDICTION. - Where a deficiency notice was mailed to a taxpayer more than two years before the executrix of her estate included her estate in an appeal which the transferee was making from a transferee notice of deficiency, the Board has no jurisdiction to hear the appeal of the executrix because it was filed long after the statutory period had expired. 2. TRANSFEREE LIABILITY. - Where prior to her death a mother transferred to her daughter without monetary consideration property having a greater value than the amount of the taxes due and such transfer left the mother insolvent, the…
1Opinion of the Court
*191OPINION.
Black :
The issues involved in this proceeding are three.(1) Has the Board jurisdiction in so far as it involves Margaret Wilson Baker, executrix of the estate of Ida Carr Addicks, for the purpose of determining whether there was an overpayment of taxes by Ida Carr Addicks during each of the taxable years in question ?(2) Is petitioner, Margaret Wilson Baker, liable as a transferee of Ida Carr Addicks for additional taxes due and unpaid by the latter for the years 1927 and 1928 ?(3) Is there any deficiency in tax due by Ida Carr Addicks for the years 1927 and 1928?
We will discuss these…
2Cases cited6 opinions
- Corliss v. BowersSupreme Court of the United States · 1930
- Cleveland v. CommissionerUnited States Board of Tax Appeals · 1933
- Keller v. CommissionerUnited States Board of Tax Appeals · 1930
- Hutton v. CommissionerUnited States Board of Tax Appeals · 1930
- Snyder v. CommissionerUnited States Board of Tax Appeals · 1933
1 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Bartmer Automatic Self Service Laundry, Inc. v. CommissionerUnited States Tax Court · 1960
- Mendelson v. Comm'rUnited States Tax Court · 1969
- Transo Oil Corp. v. CommissionerUnited States Tax Court · 1943
- Baker v. CommissionerUnited States Board of Tax Appeals · 1934
- Bartmer Automatic Self Service Laundry, Inc. v. CommissionerUnited States Tax Court · 1960
8 more not listed; retrieve them via the Exa API.