American Trust Co. v. Commissioner
United States Board of Tax Appeals
A taxpayer, residing in Missouri, in 1916 conveyed all his property by a duly recorded trust deed to trustees for the payment of his debts and the use and benefit of his children after his death, reserving to himself during his life only income therefrom.
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A taxpayer, residing in Missouri, in 1916 conveyed all his property by a duly recorded trust deed to trustees for the payment of his debts and the use and benefit of his children after his death, reserving to himself during his life only income therefrom. He died in November, 1921, having duly filed his individual income-tax return for the calendar year 1920. The Commissioner, under section 3176 of the Revised Statutes of the United States, filed return for him for the calendar year 1921. Deficiencies in income tax for 1920 and 1921 were duly assessed against his administrator, from whom…
1Opinion of the Court
*584OPINION.
Seawell:
The petitioners have pleaded the statute of limitations as a bar to the proposed assessment of a deficiency in tax.
The taxpayer, Henry B. Graham, filed an individual income-tax return for the calendar year 1920, on March 15, 1921.
He died in November, 1921, and on or about April 10, 1925, pursuant to section 3176 of the Revised Statutes of the United States, the Commissioner filed for him an income-tax return for 1921.
On or about December 28, 1925, and before the statute of limitations had run, a deficiency letter proposing for assessment additional *585income tax for 1920 and…
2Cases cited1 opinion
- McFarland v. BishopSupreme Court of Missouri · 1920
3Cited by1 opinion
- American Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1929