Lawrence v. Commissioner
United States Tax Court
1. Statute of Limitations -- Sec. 275 (c) -- 25 Per Cent Omission From Gross Income -- Omission Explained in Return. -- The 5-year period of limitations provided by section 275 (c) applies where a taxpayer omitted from gross income shown on the return a capital gain, which omission represented more than 25 per cent of the gross income shown on the return.
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1. Statute of Limitations -- Sec. 275 (c) -- 25 Per Cent Omission From Gross Income -- Omission Explained in Return. -- The 5-year period of limitations provided by section 275 (c) applies where a taxpayer omitted from gross income shown on the return a capital gain, which omission represented more than 25 per cent of the gross income shown on the return. It is immaterial that the omission was explained on a separate sheet of paper attached to the return. 2. Statute of Limitations -- Sec. 275 (c) -- Sec. 275 (e). -- The 5-year period of section 275 (c) is applicable even though the omitted…
1Opinion of the Court
Arthur L. Lawrence and Alma P. Lawrence, Petitioners, v. Commissioner of Internal Revenue, Respondent
Lawrence v. Commissioner
Docket No. 53929
United States Tax Court
27 T.C. 713; 1957 U.S. Tax Ct. LEXIS 276;
January 25, 1957, Filed
Decision will be entered for the respondent.
1. Statute of Limitations -- Sec. 275 (c) -- 25 Per Cent Omission From Gross Income -- Omission Explained in Return. -- The 5-year period of limitations provided by section 275 (c) applies where a taxpayer omitted from gross income shown on the return a capital gain, which omission represented more than 25 per cent of the…
2Cases cited55 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Reis v. CommissionerUnited States Tax Court · 1942
- Lawrence v. CommissionerUnited States Tax Court · 1957
- Reis v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1944
- Colony, Inc. v. CommissionerUnited States Tax Court · 1956
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