Rose v. Commissioner
United States Tax Court
1. Deficiency notices were sent more than 3 years but within a 5-year period (as extended by waivers) after income tax returns for 1943 had been filed. Held, assessment of deficiencies barred.
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1. Deficiency notices were sent more than 3 years but within a 5-year period (as extended by waivers) after income tax returns for 1943 had been filed. Held, assessment of deficiencies barred. In determining whether there had been an omission of more than 25 per cent of gross income within the meaning of section 275 (c), 1939 Code, the individual returns filed by petitioners must be considered together with a partnership return that was filed with respect to a business owned by them as community property where the partnership return had been filed merely to facilitate the reporting of their…
1Opinion of the Court
Jack Rose, Petitioner, v. Commissioner of Internal Revenue, Respondent. Mae Rose, Petitioner, v. Commissioner of Internal Revenue, Respondent. Jack Rose and Mae Rose, Petitioners, v. Commissioner of Internal Revenue, Respondent
Rose v. Commissioner
Docket Nos. 43652, 43653, 43654
United States Tax Court
24 T.C. 755; 1955 U.S. Tax Ct. LEXIS 129;
July 27, 1955, Filed
Decisions will be entered under Rule 50.
1. Deficiency notices were sent more than 3 years but within a 5-year period (as extended by waivers) after income tax returns for 1943 had been filed. Held, assessment of deficiencies barred. In…
2Cases cited21 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- Switzer v. CommissionerUnited States Tax Court · 1953
- Saulsbury v. United StatesCourt of Appeals for the Fifth Circuit · 1952
- Uptegrove Lumber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
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