Lawton v. Commissioner
United States Tax Court
Held, under the facts presented, respondent was not barred from determining a deficiency for the years in question within the statutory period even though he had previously determined overassessments for those same years.
1Opinion of the Court
OPINION.
Hill, Judge:
The respondent determined deficiencies in petitioners’ income taxes as follows:
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The only question for determination here is whether respondent having once determined an overassessment with respect to one of the petitioners’ taxes for the year ended December 31, 1940, and with respect to all of the petitioners for the year ended December 31, 1941, may legally thereafter within the permissible period of limitations prescribed by statute determine a deficiency for these years against each of the petitioners. An issue that the deficiency determined for the year…
2Cases cited4 opinions
- Royal Indemnity Co. v. United StatesSupreme Court of the United States · 1941
- Burnet v. PorterSupreme Court of the United States · 1931
- McIlhenny v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1930
- Fleming v. CommissionerUnited States Tax Court · 1944
3Cited by8 opinions
- Opine Timber Co. v. CommissionerUnited States Tax Court · 1975
- Meridian Mut. Ins. Co. v. CommissionerUnited States Tax Court · 1965
- Vlock v. Comm'rUnited States Tax Court · 2010
- Fitzpatrick v. CommissionerUnited States Tax Court · 1995
- Ulanoff v. CommissionerUnited States Tax Court · 1999
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