Hewitt-Robins Inc. v. Commissioner
United States Tax Court
Petitioner filed timely applications for relief under section 722(b)(2), (3), and (5), for the years 1940, 1941, and 1942, based upon alleged facts external to petitioner. After expiration of the statutory period for filing original claims for said years, petitioner filed purported amendments, seeking relief under section 722(b)(4), and alleging certain changes internal to petitioner in or immediately prior to the base period.
Read the full summary
Petitioner filed timely applications for relief under section 722(b)(2), (3), and (5), for the years 1940, 1941, and 1942, based upon alleged facts external to petitioner. After expiration of the statutory period for filing original claims for said years, petitioner filed purported amendments, seeking relief under section 722(b)(4), and alleging certain changes internal to petitioner in or immediately prior to the base period. Held: The claims under section 722(b)(4) are outside the scope of the investigation called for by the original claims and supporting material submitted within the…
1Opinion of the Court
Hewitt-Robins Incorporated (Successor by Merger to Robins Conveyors Incorporated), Petitioner, v. Commissioner of Internal Revenue, Respondent
Hewitt-Robins Inc. v. Commissioner
Docket No. 39101
United States Tax Court
32 T.C. 60; 1959 U.S. Tax Ct. LEXIS 201;
April 10, 1959, Filed
Decision will be entered for the respondent.
Petitioner filed timely applications for relief under section 722(b)(2), (3), and (5), for the years 1940, 1941, and 1942, based upon alleged facts external to petitioner. After expiration of the statutory period for filing original claims for said years, petitioner filed…
2Cases cited12 opinions
- United States v. Memphis Cotton Oil Co.Supreme Court of the United States · 1933
- George Moore Ice Cream Co. v. RoseSupreme Court of the United States · 1933
- United States v. KalesSupreme Court of the United States · 1941
- United States v. Garbutt Oil Co.Supreme Court of the United States · 1938
- United States v. AndrewsSupreme Court of the United States · 1938
7 more not listed; retrieve them via the Exa API.