Legal Opinion

Heyl v. Commissioner

United States Board of Tax Appeals

Decided March 26, 1936No. Docket No. 79364Published

1. STATUTE OF LIMITATIONS. - No returns of income having been filed by or on behalf of petitioner for the years 1918 and 1921, during which time his property was in the custody of the Alien Property Custodian, it is held that the assessment and collection of a deficiency determined by the respondent in 1935 is not barred by the statute of limitations. 2. JURISDICTION. - This Board has no power to require the application of an overpayment, made during a year other than those…

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1. STATUTE OF LIMITATIONS. - No returns of income having been filed by or on behalf of petitioner for the years 1918 and 1921, during which time his property was in the custody of the Alien Property Custodian, it is held that the assessment and collection of a deficiency determined by the respondent in 1935 is not barred by the statute of limitations. 2. JURISDICTION. - This Board has no power to require the application of an overpayment, made during a year other than those for which the respondent has determined a deficiency, to the liquidation of the tax liability for the years involved in…

1Opinion of the Court

HELMUTH HEYL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Heyl v. Commissioner

Docket No. 79364.

United States Board of Tax Appeals

34 B.T.A. 223; 1936 BTA LEXIS 731;

March 26, 1936, Promulgated

1. STATUTE OF LIMITATIONS. - No returns of income having been filed by or on behalf of petitioner for the years 1918 and 1921, during which time his property was in the custody of the Alien Property Custodian, it is held that the assessment and collection of a deficiency determined by the respondent in 1935 is not barred by the statute of limitations.

2. JURISDICTION. - This Board has no…

2Cases cited9 opinions

  1. Bull v. United StatesSupreme Court of the United States · 1935
  2. Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
  3. Lucas v. Pilliod Lumber Co.Supreme Court of the United States · 1930
  4. W. M. Ritter Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  5. Greenleaf Textile Corp. v. CommissionerUnited States Board of Tax Appeals · 1932

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