Legal Opinion

Insulglass Corp. v. Commissioner

United States Tax Court

Decided February 13, 1985No. Docket No. 19733-83Published

The notice of deficiency was issued more than 3, but less than 6, years after petitioners' 1976 return was filed. In a motion for partial summary judgment, petitioners contend that the 6-year statute under sec. 6501(e)(1)(A), I.R.C. 1954, does not apply. For purposes of the motion, petitioners concede that there were items of gross income omitted from their 1976 return.

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The notice of deficiency was issued more than 3, but less than 6, years after petitioners' 1976 return was filed. In a motion for partial summary judgment, petitioners contend that the 6-year statute under sec. 6501(e)(1)(A), I.R.C. 1954, does not apply. For purposes of the motion, petitioners concede that there were items of gross income omitted from their 1976 return. Held: Petitioners' motion for partial summary judgment denied. 1. The fact that agents of respondent discovered the items of omitted income during the audit and prior to the expiration of the usual 3-year statute does not…

1Opinion of the Court

Insulglass Corporation, Winter Seal of Flint, Inc., James Ninowski, Jr., and Judith Ninowski, Petitioners v. Commissioner of Internal Revenue, Respondent

Insulglass Corp. v. Commissioner

Docket No. 19733-83

United States Tax Court

84 T.C. 203; 1985 U.S. Tax Ct. LEXIS 121; 84 T.C. No. 16;

February 13, 1985. February 13, 1985, Filed

The notice of deficiency was issued more than 3, but less than 6, years after petitioners' 1976 return was filed. In a motion for partial summary judgment, petitioners contend that the 6-year statute under sec. 6501(e)(1)(A), I.R.C. 1954, does not apply. For purposes of…

2Cases cited9 opinions

  1. Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
  2. Roschuni v. CommissionerUnited States Tax Court · 1965
  3. Goldring v. CommissionerUnited States Tax Court · 1953
  4. Houston v. CommissionerUnited States Tax Court · 1962
  5. Estate of Herman Klein, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976

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