Legal Opinion

Gatto v. Commissioner

United States Tax Court

Decided July 17, 1953No. Docket No. 37206Published

1. Respondent determined that petitioner is liable as transferee for her husband's taxes for 1944 and 1945. The period of limitation for the transferor was extended for both years by agreement to June 30, 1950. Held, that the statute of limitations for determining transferee liability is 1 year after the expiration of the period against the transferor as properly extended by agreements.

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1. Respondent determined that petitioner is liable as transferee for her husband's taxes for 1944 and 1945. The period of limitation for the transferor was extended for both years by agreement to June 30, 1950. Held, that the statute of limitations for determining transferee liability is 1 year after the expiration of the period against the transferor as properly extended by agreements. A jeopardy assessment was made against petitioner on June 22, 1951. The deficiency notice was mailed July 19, 1951. Held, further, since the jeopardy assessment was made within the applicable statute of…

1Opinion of the Court

Anne Gatto, Transferee, Petitioner, v. Commissioner of Internal Revenue, Respondent

Gatto v. Commissioner

Docket No. 37206

United States Tax Court

20 T.C. 830; 1953 U.S. Tax Ct. LEXIS 88;

July 17, 1953, Promulgated

Decision will be entered under Rule 50.

1. Respondent determined that petitioner is liable as transferee for her husband's taxes for 1944 and 1945. The period of limitation for the transferor was extended for both years by agreement to June 30, 1950. Held, that the statute of limitations for determining transferee liability is 1 year after the expiration of the period against the…

2Cases cited9 opinions

  1. Gobins v. Comm'rUnited States Tax Court · 1952
  2. COMMISSIONER OF INT. REVENUE v. Oswego Falls Corp.Court of Appeals for the Second Circuit · 1934
  3. Rite-Way Products, Inc. v. CommissionerUnited States Tax Court · 1949
  4. Hutton v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1932
  5. Powers Photo Engraving Co. v. CommissionerUnited States Tax Court · 1951

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