United States Holding Co. v. Commissioner
United States Tax Court
1. Respondent, after examining Pasadena's books and records for the years 1954-56, proposed certain adjustments. These adjustments were subsequently settled under administrative procedures. Thereafter, without giving proper written notice pursuant to section 7605(b), I.R.C. 1954, respondent requested permission to reexamine Pasadena's books for the same years.
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1. Respondent, after examining Pasadena's books and records for the years 1954-56, proposed certain adjustments. These adjustments were subsequently settled under administrative procedures. Thereafter, without giving proper written notice pursuant to section 7605(b), I.R.C. 1954, respondent requested permission to reexamine Pasadena's books for the same years. Such request was denied, whereupon respondent, without the aid of Pasadena's books, proposed additional adjustments for the years 1954 and 1956 which became the basis of the notice of deficiency in this case. Held, since respondent did…
1Opinion of the Court
OPINION
Fay, Judge:
The Commissioner determined deficiencies in income tax for the taxable years 1954 and 1956 against Pasadena First National Bank, a transferor corporation, in the respective amounts of $22,988.70 and $295,430.78. This proceeding involves the liability of the petitioner as transferee of the assets of the aforementioned trans-f eror corporation.1 The parties by agreement have disposed of certain issues raised by the pleadings. The first issue for decision is whether the proposed deficiencies are improper, illegal, and invalid because of the Commissioner’s alleged violation of…
2Cases cited26 opinions
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Charles Oran Mensik and Mary Mensik v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Mensik v. CommissionerUnited States Tax Court · 1962
- William O'Dwyer and Sloan O'Dwyer v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959
21 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Durovic v. CommissionerUnited States Tax Court · 1970
- Cathy Miller Hardy v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
- Rolfs v. Comm'rUnited States Tax Court · 2010
- Ballantine v. CommissionerUnited States Tax Court · 1980
- Vern Realty, Inc. v. CommissionerUnited States Tax Court · 1972
24 more not listed; retrieve them via the Exa API.