Legal Opinion

Jaffee v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided December 8, 1930No. 10PublishedCited by 20 opinions

1Opinion of the CourtChase, Circuit Judge

(after stating the facts as above).

The petitioner claims that all waivers signed by Charles D. Jaffee are invalid because he was not shown -to have had authority to execute them in behalf of the taxpayer, Schwartz & Jaffee, Inc. As the statutory period within which the assessment could be made had expired before April, 1926, it is apr parent that, if the waivers are invalid, the assessment was void.

Upon the dissolution of the corporation March 8, 1922, the winding up- of its affairs devolved, under the New York law, upon its board of directors, and its corporate existence was continued only…

2Cases cited9 opinions

  1. Smith v. AyerSupreme Court of the United States · 1880
  2. Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
  3. Liberty Baking Co. v. HeinerCourt of Appeals for the Third Circuit · 1930
  4. Armstrong v. AshleySupreme Court of the United States · 1907
  5. Joy Floral Co. v. CommissionerCourt of Appeals for the D.C. Circuit · 1928

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3Cited by20 opinions

  1. Sidney Kreps v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
  2. O'Sullivan Rubber Co. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1941
  3. Cary v. CommissionerUnited States Tax Court · 1967
  4. United States v. KruegerCourt of Appeals for the Third Circuit · 1941
  5. Continental Oil Co. v. United StatesUnited States Court of Claims · 1936

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