Gould-Mersereau Co. v. Commissioner
United States Board of Tax Appeals
1. The period for assessment having been extended by a consent in writing, deficiencies asserted within the period as so extended are not barred from assessment and collection. 2. The action of the Commissioner will not be disturbed where no error with respect thereto was asserted in the pleadings nor tried at the hearing and where it was raised for the first time in the brief filed for petitioner. 3. The presumption that the action of the Commissioner is correct is not…
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1. The period for assessment having been extended by a consent in writing, deficiencies asserted within the period as so extended are not barred from assessment and collection. 2. The action of the Commissioner will not be disturbed where no error with respect thereto was asserted in the pleadings nor tried at the hearing and where it was raised for the first time in the brief filed for petitioner. 3. The presumption that the action of the Commissioner is correct is not overcome by the submission in evidence of a revenue agent's report which the Commissioner did not follow. Nor will the Board…
1Opinion of the Court
GOULD-MERSEREAU CO., INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT
Gould-Mersereau Co. v. Commissioner
Docket No. 18207.
United States Board of Tax Appeals
21 B.T.A. 1316; 1931 BTA LEXIS 2211;
January 22, 1931, Promulgated
1. The period for assessment having been extended by a consent in writing, deficiencies asserted within the period as so extended are not barred from assessment and collection.
2. The action of the Commissioner will not be disturbed where no error with respect thereto was asserted in the pleadings nor tried at the hearing and where it was raised for the first…
2Cases cited16 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Russell v. United StatesSupreme Court of the United States · 1929
- Duffy v. Central R. Co. of NJSupreme Court of the United States · 1925
- Lovejoy v. CommissionerUnited States Board of Tax Appeals · 1930
- Bonwit Teller & Co. v. CommissionerUnited States Board of Tax Appeals · 1929
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