Legal Opinion

Harrington v. Commissioner

United States Tax Court

Decided September 29, 1967No. Docket No. 3061-64PublishedCited by 16 opinions

1. Following an initial audit, petitioners received a communication from the district director of internal revenue stating that their returns for 1959 and 1960 would be accepted as filed.

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1. Following an initial audit, petitioners received a communication from the district director of internal revenue stating that their returns for 1959 and 1960 would be accepted as filed. Held, this routine letter did not constitute a closing agreement under sec. 7121, I.R.C. 1954 2. Held, further: A reexamination of petitioners' returns and records for the years 1959 and 1960 did not violate sec. 7605 (b), I.R.C. 1954. Petitioners acquiesced in the examination, and, in any event, respondent literally satisfied the provisions of the statute permitting such a reaudit when the taxpayer was…

1Opinion of the Court

Hott, Judge:

The respondent determined the following income tax deficiencies against the petitioners:

Year Deficiency

1959 _$11, 778. 23

1960 _ 7,401. 92

1961_ 12, 500. 37

After concessions by the parties the only issues remaining for our determination are:(1) Whether the petitioners are entitled to certain depletion deductions claimed with respect to oil produced from illegally deviated oil wells bottomed outside of leased property in which they held interests in the East Texas and Hawkins fields.(2) Whether respondent’s determinations for 1959 and 1960 are invalid because they resulted from a…

2Cases cited15 opinions

  1. Palmer v. BenderSupreme Court of the United States · 1932
  2. Anderson v. HelveringSupreme Court of the United States · 1940
  3. Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
  4. Helvering v. Bankline Oil Co.Supreme Court of the United States · 1938
  5. Parsons v. SmithSupreme Court of the United States · 1959

10 more not listed; retrieve them via the Exa API.

3Cited by16 opinions

  1. Emma R. Dorl v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1974
  2. Hudock v. CommissionerUnited States Tax Court · 1975
  3. Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1975
  4. Estate of Meyer v. CommissionerUnited States Tax Court · 1972
  5. Hedrick v. CommissionerUnited States Tax Court · 1974

11 more not listed; retrieve them via the Exa API.

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