Legal Opinion

Whirlpool Corp. v. Commissioner

United States Tax Court

Decided November 8, 1973No. Docket No. 8868-72PublishedCited by 18 opinions

The petitioner filed its Federal income tax return for the year 1968 on Sept. 12, 1969. On Sept. 12, 1972, the respondent mailed to the petitioner a notice of deficiency respecting its tax liability for 1968. Held, under sec. 6503(a)(1), I.R.C. 1954, the statute of limitations for assessment of income taxes for 1968 was suspended by the mailing of the notice of deficiency.

1Opinion of the Court

OPINION

Simpson, Judge:

The respondent determined the following deficiencies in the petitioner’s Federal income taxes:

Hear Deficiency

1968 -$4,196, 870

1969 _ 64,697

The issue to be decided at this time is whether a notice of deficiency, which was mailed on the final day for the assessment of a deficiency, suspends the period for the assessment of such deficiency.

The petitioner, Whirlpool Corp. (Whirlpool), was a Delaware corporation and had its principal place of business at Benton Harbor, Mich., at the time of filing its petition herein. It filed its Federal income tax returns for the years 1968…

2Cases cited14 opinions

  1. United States v. CorrellSupreme Court of the United States · 1967
  2. Brewster v. GageSupreme Court of the United States · 1930
  3. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
  4. Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
  5. Helvering v. WinmillSupreme Court of the United States · 1938

9 more not listed; retrieve them via the Exa API.

3Cited by18 opinions

  1. Frieling v. CommissionerUnited States Tax Court · 1983
  2. Block v. Comm'rUnited States Tax Court · 2003
  3. Julia R. & Estelle L. Foundation, Inc. v. CommissionerUnited States Tax Court · 1978
  4. Cornman v. CommissionerUnited States Tax Court · 1975
  5. Hall v. CommissionerUnited States Tax Court · 1976

13 more not listed; retrieve them via the Exa API.

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