Legal Opinion
The Colony, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided April 22, 1957No. 13008PublishedCited by 62 opinions
1Per curiam
The sole question on this review is whether the five-year statute of limitations contained in section 275(c) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 275(c) was applicable, in this case, as the Tax Court held. 1
The petitioner is a corporation dealing in real estate. Its income tax returns for the years in question contained understatements of gross income of more than twenty-five per cent resulting from an erroneous overstatement of the basis 'of land sold, rather than from any omission of gross receipts. Under these circumstances it is the petitioner’s contention that the general…
2Cases cited6 opinions
- Reis v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1944
- Uptegrove Lumber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
- Deakman-Wells Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1954
- George Slaff v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- William E. Davis, Former Collector of Internal Revenue for the District of Alabama v. C. B. Hightower, Jr.Court of Appeals for the Fifth Circuit · 1956
1 more not listed; retrieve them via the Exa API.
3Cited by62 opinions
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Aldon Homes, Inc. v. CommissionerUnited States Tax Court · 1959
- Arthur L. Lawrence and Alma P. Lawrence v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Bakersfield Energy Partners, LP v. CommissionerCourt of Appeals for the Ninth Circuit · 2009
- Bakersfield Energy Partners, LP v. Comm'rUnited States Tax Court · 2007
57 more not listed; retrieve them via the Exa API.