Whirlpool Corp. v. Commissioner
United States Tax Court
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
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