National Water Main Cleaning Co. v. Commissioner
United States Board of Tax Appeals
1. The power to consent to an extension of time for the determination, assessment, and collection of taxes as provided under the revenue acts is within the ordinary functions of a corporation and need not be expressly conferred upon its general officers, and quaere whether the consent is to be treated or construed as a contract and hedged about with the legal rules governing contracts. 2. The Commissioner is authorized to delegate the power to consent in writing to a…
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1. The power to consent to an extension of time for the determination, assessment, and collection of taxes as provided under the revenue acts is within the ordinary functions of a corporation and need not be expressly conferred upon its general officers, and quaere whether the consent is to be treated or construed as a contract and hedged about with the legal rules governing contracts. 2. The Commissioner is authorized to delegate the power to consent in writing to a subordinate, and, where he authorizes a subordinate to sign his name and treats the consent as his own, the authorization…
1Opinion of the Court
NATIONAL WATER MAIN CLEANING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
National Water Main Cleaning Co. v. Commissioner
Docket No. 12140.
United States Board of Tax Appeals
16 B.T.A. 223; 1929 BTA LEXIS 2614;
April 26, 1929, Promulgated
1. The power to consent to an extension of time for the determination, assessment, and collection of taxes as provided under the revenue acts is within the ordinary functions of a corporation and need not be expressly conferred upon its general officers, and quaere whether the consent is to be treated or construed as a contract and hedged…
2Cases cited13 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- City of New York v. SageSupreme Court of the United States · 1915
- Farmers Feed Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- L. S. Ayers & Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- Russel Wheel & Foundry Co. v. CommissionerUnited States Board of Tax Appeals · 1926
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