Legal Opinion
Daniel M. Cory and Margot Cory, His Wife v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided December 1, 1958No. 61, Docket 25192PublishedCited by 21 opinions
1Opinion of the Court
CLARK, Chief Judge.
On this review of a Tax Court decision finding a deficiency of $15,204.97 in their income tax for 1945, petitioners rely on the statute of limitations. Although the notice of deficiency was issued December 20, 1956 — more than ten years after the return was filed — the Tax Court found the assessment timely under I.R.C.1954, §§ 1311-1314, 26 U.S.C. §§ 1311-1314, which under stated conditions allow an additional one-year period for assessment of tax upon certain items of income. 29 T.C. 903. The petitioners now challenge this ruling.
In their 1944 return taxpayers had reported…
2Cases cited6 opinions
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Helvering v. PfeifferSupreme Court of the United States · 1937
- Rosenthal v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
- Daniel M. Cory and Margot Cory, His Wife, Petitioners-On-Review v. Commissioner of Internal Revenue, Respondent-On-ReviewCourt of Appeals for the Second Circuit · 1956
- Cory v. CommissionerUnited States Tax Court · 1958
1 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Yagoda v. CommissionerUnited States Tax Court · 1962
- A. H. Karpe v. The United States. The United States (Cross-Complainant) v. Birda M. Viera (Cross-Defendant)United States Court of Claims · 1964
- William E. And Thelma S. Dobson v. The United StatesUnited States Court of Claims · 1964
- Olaf E. Taxeraas, Administrator of the Estate of Carl Taxeraas and Irene Taxeraas v. United StatesCourt of Appeals for the Eighth Circuit · 1959
- Yagoda v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
16 more not listed; retrieve them via the Exa API.