Legal Opinion

E. M. Pringle Naval Stores Co. v. Commissioner

United States Board of Tax Appeals

Decided August 27, 1931No. Docket No. 32489Published

A waiver of the statute of limitations covering the calendar year 1921 and given by a taxpayer to his attorney, who holds a power of attorney authorizing him "generally to do, execute, and perform every act and thing whatever necessary or proper to be done with respect to the premises" for the year 1920 as well as for 1921, and who changes the waiver to cover the year 1920, and then gives it to the Commissioner, who accepts it, is a valid waiver extending the time within…

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A waiver of the statute of limitations covering the calendar year 1921 and given by a taxpayer to his attorney, who holds a power of attorney authorizing him "generally to do, execute, and perform every act and thing whatever necessary or proper to be done with respect to the premises" for the year 1920 as well as for 1921, and who changes the waiver to cover the year 1920, and then gives it to the Commissioner, who accepts it, is a valid waiver extending the time within which an assessment of deficiency for 1920 may be made.

1Opinion of the Court

E. M. PRINGLE NAVAL STORES COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

E. M. Pringle Naval Stores Co. v. Commissioner

Docket No. 32489.

United States Board of Tax Appeals

23 B.T.A. 1328; 1931 BTA LEXIS 1727;

August 27, 1931, Promulgated

A waiver of the statute of limitations covering the calendar year 1921 and given by a taxpayer to his attorney, who holds a power of attorney authorizing him "generally to do, execute, and perform every act and thing whatever necessary or proper to be done with respect to the premises" for the year 1920 as well as for 1921, and who…

2Cases cited1 opinion

  1. E. M. Pringle Naval Stores Co. v. CommissionerUnited States Board of Tax Appeals · 1931

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