Legal Opinion

Gulf States Steel Co. v. Commissioner

United States Board of Tax Appeals

Decided July 10, 1928No. Docket Nos. 9276, 18358, 18359Published

STATUTE OF LIMITATIONS. - The filing of a bond with an abatement claim does not satisfy the provision of section 250(d) of the Revenue Act of 1921 requiring a consent in writing by both the Commissioner and the taxpayer as a condition precedent to the postponement of the collection beyond five years after the date the return was filed.

1Opinion of the Court

GULF STATES STEEL CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Gulf States Steel Co. v. Commissioner

Docket Nos. 9276, 18358, 18359.

United States Board of Tax Appeals

12 B.T.A. 1244; 1928 BTA LEXIS 3374;

July 10, 1928, Promulgated

STATUTE OF LIMITATIONS. - The filing of a bond with an abatement claim does not satisfy the provision of section 250(d) of the Revenue Act of 1921 requiring a consent in writing by both the Commissioner and the taxpayer as a condition precedent to the postponement of the collection beyond five years after the date the return was filed.

John Drye, Jr.,…

2Cases cited5 opinions

  1. Dollar Savings Bank v. United StatesSupreme Court of the United States · 1874
  2. Bowers v. New York & Albany Lighterage Co.Supreme Court of the United States · 1927
  3. Art Metal Works v. CommissionerUnited States Board of Tax Appeals · 1927
  4. Shaffer v. CommissionerUnited States Board of Tax Appeals · 1928
  5. Gulf States Steel Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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