Legal Opinion

Bradford Co. v. Commissioner

United States Board of Tax Appeals

Decided November 19, 1928No. Docket No. 8384PublishedCited by 1 opinion

1. Collection of the additional taxes involved herein is not barred by the statute of limitations. 2. The petitioner is entitled to have its excess-profits taxes for the year 1917 computed under section 209 of the Revenue Act of 1917.

1Opinion of the Court

*343OPINION.

Marquette :

This proceeding raises two questions for our determination, namely: (1) Is collection of the additional tax asserted by the respondent for the year 1917 barred by the statute of limitations, and (2) is the petitioner .entitled to have its excess-profits tax computed under section 209 of the Revenue Act of 1917 ? The questions will be discussed in the order in which they are stated.

*344The record discloses that the petitioner’s income and profits-tax return for 1917 was filed on June 14, 1918. The statutory period of five years from the date the return was filed provided by the…

2Cases cited4 opinions

  1. De Laski & Thropp Circular Woven Tire Co. v. IredellDistrict Court, D. New Jersey · 1920
  2. Iredell v. De Laski & Thropp Circular Woven Tire Co.Court of Appeals for the Third Circuit · 1923
  3. Cartier v. DoyleCourt of Appeals for the Sixth Circuit · 1921
  4. Empire Fuel Co. v. HaysDistrict Court, N.D. West Virginia · 1924

3Cited by1 opinion

  1. Bradford Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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