Legal Opinion

Albert Lea Packing Co. v. Commissioner

United States Board of Tax Appeals

Decided October 21, 1931No. Docket Nos. 20765-20776Published

1. Additional taxes for 1917, timely assessed in 1922 and 1923, held uncollectible under the decision in Russell v. United States,278 U.S. 181. 2. In the case of one petitioner, Wilson & Company, Inc., of California, claim in abatement was filed, collection stayed, and the tax collected by distraint warrant after the statute had run against collection and after a petition for redetermination had been filed with the Board.

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1. Additional taxes for 1917, timely assessed in 1922 and 1923, held uncollectible under the decision in Russell v. United States,278 U.S. 181. 2. In the case of one petitioner, Wilson & Company, Inc., of California, claim in abatement was filed, collection stayed, and the tax collected by distraint warrant after the statute had run against collection and after a petition for redetermination had been filed with the Board. Held, that section 611 of the Revenue Act of 1928 is a limitation on section 284(e) of the Revenue Act of 1926 and section 507 of the Revenue Act of 1928, and bars recovery…

1Opinion of the Court

ALBERT LEA PACKING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

PENNSYLVANIA INVESTORS COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

WILSON COMMISSION COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

WILSON & COMPANY, INC., OF CALIFORNIA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

UNION LARD CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

STANDARD BEEF COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. SELLS SPORTING GOODS COMPANY, PETITIONER, v. COMMISSIONER OF…

2Cases cited21 opinions

  1. Graham & Foster v. GoodcellSupreme Court of the United States · 1931
  2. Russell v. United StatesSupreme Court of the United States · 1929
  3. United States v. ChaseSupreme Court of the United States · 1890
  4. Townsend v. LittleSupreme Court of the United States · 1883
  5. Atkins v. Disintegrating Co.Supreme Court of the United States · 1874

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