Krug v. Commissioner
United States Board of Tax Appeals
Under the principles announced in United States v. Updike,281 U.S. 489, in the present case, where no return was made by transferor company for the year 1918 but an assessment against it was made in 1922, the period of limitations respecting the transferee began to run at the date of assessment and bars enforcement of the liability against transferee on a notice of liability issued October 29, 1929.
1Opinion of the Court
GEORGE F. KRUG, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Krug v. Commissioner
Docket No. 46713.
United States Board of Tax Appeals
30 B.T.A. 1376; 1934 BTA LEXIS 1189;
July 31, 1934, Promulgated
Under the principles announced in United States v. Updike,281 U.S. 489, in the present case, where no return was made by transferor company for the year 1918 but an assessment against it was made in 1922, the period of limitations respecting the transferee began to run at the date of assessment and bars enforcement of the liability against transferee on a notice of liability issued…
2Cases cited2 opinions
- United States v. UpdikeSupreme Court of the United States · 1930
- Krug v. CommissionerUnited States Board of Tax Appeals · 1934