Ekdahl v. Commissioner
United States Board of Tax Appeals
In the circumstances herein the waiver produced by the respondent is without effect to stay the statute of limitations as to the petitioner's income-tax return for 1920.
1Opinion of the Court
*1231OPINION.
Lansdon:
The petitioner timely filed a Federal income-tax return for 1920 on March 15, 1921. It is stipulated that such return *1232included the income and deductions of both husband and wife, and that it was made by the husband. The notice of deficiency was mailed to the petitioner on or about December 18, 1926, which was more than five years after the filing of the return. There is no proof of any assessment prior to the deficiency notice. It is stipulated that the petitioner at no time filed any waiver extending the statutory period for assessing any deficiency for 1920. The petitioner…
2Cited by12 opinions
- Dolan v. CommissionerUnited States Tax Court · 1965
- Tallal v. CommissionerUnited States Tax Court · 1981
- Mark Buchine v. Commissioner of Internal Revenue Service, Karen C. Buchine v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1994
- United States v. Gordon C. Borchardt, Charles Oran MensikCourt of Appeals for the Seventh Circuit · 1972
- Estate of Sperling v. CommissionerUnited States Tax Court · 1963
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