Lorie v. Commissioner
United States Board of Tax Appeals
1. The constitutionality of section 280, Revenue Act of 1926, will not be considered in a proceeding brought by one against whom a liability as a transferee has been assessed. 2. Where an assessment for 1920 was made before the passage of the Revenue Act of 1924 and the statutory period for collection expired after its passage and before the enactment of the Revenue Act of 1926, the provision of the 1924 Act extending the period for collection to six years after assessment…
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1. The constitutionality of section 280, Revenue Act of 1926, will not be considered in a proceeding brought by one against whom a liability as a transferee has been assessed. 2. Where an assessment for 1920 was made before the passage of the Revenue Act of 1924 and the statutory period for collection expired after its passage and before the enactment of the Revenue Act of 1926, the provision of the 1924 Act extending the period for collection to six years after assessment is inapplicable and the right to collection is not revived by the 1926 Act. 3. A transferee seeking to prove freedom from…
1Opinion of the Court
E. J. LORIE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
PHILIP GOLDENBERG, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Lorie v. Commissioner
Docket Nos. 27526, 27527.
United States Board of Tax Appeals
21 B.T.A. 612; 1930 BTA LEXIS 1825;
December 10, 1930, Promulgated
1. The constitutionality of section 280, Revenue Act of 1926, will not be considered in a proceeding brought by one against whom a liability as a transferee has been assessed.
2. Where an assessment for 1920 was made before the passage of the Revenue Act of 1924 and the statutory period for collection…
2Cases cited1 opinion
- Lorie v. CommissionerUnited States Board of Tax Appeals · 1930