Paso Robles Mercantile Co. v. Commissioner
United States Board of Tax Appeals
The petitioner kept its books on a fiscal year basis but filed its return on a calendar year basis. Held, that the return filed on the calendar year basis, which did not include the full taxable period, did not start the running of the statute of limitations.
1Opinion of the Court
*751OPINION.
Trammell:
While the petitioner has included the years 1920 and 1922, there were no deficiencies asserted for those years and the proceeding is accordingly dismissed with respect thereto, leaving only the deficiency for 1919 and the so-called deficiency for 1921.
The first assignment of error urged bjr the petitioner is that at the time the additional assessment was made by the respondent for the fiscal year ended January 31, 1919, the statute of limitations had run, therefore, this was not only an illegal assessment, but also collection of any q>art of such assessment is now barred. No…
2Cases cited2 opinions
- Edwards v. DouglasSupreme Court of the United States · 1925
- Mason v. RoutzahnSupreme Court of the United States · 1927
3Cited by8 opinions
- Century Data Systems, Inc. v. CommissionerUnited States Tax Court · 1983
- Bradstreet Co. of Maine v. CommissionerUnited States Board of Tax Appeals · 1931
- Cantrell & Cochrane v. CommissionerUnited States Board of Tax Appeals · 1930
- Century Data Systems, Inc. v. CommissionerUnited States Tax Court · 1983
- Estate of Simpson v. CommissionerUnited States Tax Court · 1994
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