Metcalf v. Commissioner
United States Board of Tax Appeals
The petitioner offered to compromise an additional assessment asserted against him and tendered $500 with said offer prior to the expiration of the period of limitation, which offer was rejected, but the amount so tendered was not returned to him. In December of 1924, after the period of limitation had expired, the petitioner authorized the respondent to apply the $500 toward the payment of a portion of his liability.
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The petitioner offered to compromise an additional assessment asserted against him and tendered $500 with said offer prior to the expiration of the period of limitation, which offer was rejected, but the amount so tendered was not returned to him. In December of 1924, after the period of limitation had expired, the petitioner authorized the respondent to apply the $500 toward the payment of a portion of his liability. Held, it was not until after the period of limitation that the said amount became "paid" within the meaning of section 607 of the Revenue Act of 1928, and it, therefore,…
1Opinion of the Court
MORRIS METCALF, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Metcalf v. Commissioner
Docket No. 25479.
United States Board of Tax Appeals
16 B.T.A. 881; 1929 BTA LEXIS 2496;
June 4, 1929, Promulgated
The petitioner offered to compromise an additional assessment asserted against him and tendered $500 with said offer prior to the expiration of the period of limitation, which offer was rejected, but the amount so tendered was not returned to him. In December of 1924, after the period of limitation had expired, the petitioner authorized the respondent to apply the $500 toward the…
2Cases cited1 opinion
- Metcalf v. CommissionerUnited States Board of Tax Appeals · 1929