Legal Opinion

Chattanooga Coke & Gas Co. v. Commissioner

United States Board of Tax Appeals

Decided June 22, 1928No. Docket No. 8317Published

1. Petitioner filed its income and profits-tax return for 1919 on or before March 15, 1920; thereafter on or about January 26, 1924, it entered into a consent in writing extending the time within which assessment of the tax for that year might be made until December 31, 1925; a deficiency notice was mailed to the petitioner on August 24, 1925, and on October 22, 1925, it filed an appeal with this Board.

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1. Petitioner filed its income and profits-tax return for 1919 on or before March 15, 1920; thereafter on or about January 26, 1924, it entered into a consent in writing extending the time within which assessment of the tax for that year might be made until December 31, 1925; a deficiency notice was mailed to the petitioner on August 24, 1925, and on October 22, 1925, it filed an appeal with this Board. Held, the collection of the deficiency for 1919 is not barred by the statute of limitations. Following Sunshine Cloak & Suit Co.,10 B.T.A. 971. 2. Commissioner Williams held that the…

1Opinion of the Court

CHATTANOOGA COKE & GAS CO., INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Chattanooga Coke & Gas Co. v. Commissioner

Docket No. 8317.

United States Board of Tax Appeals

12 B.T.A. 782; 1928 BTA LEXIS 3462;

June 22, 1928, Promulgated

1. Petitioner filed its income and profits-tax return for 1919 on or before March 15, 1920; thereafter on or about January 26, 1924, it entered into a consent in writing extending the time within which assessment of the tax for that year might be made until December 31, 1925; a deficiency notice was mailed to the petitioner on August 24, 1925, and on…

2Cases cited2 opinions

  1. Sunshine Cloak & Suit Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  2. Chattanooga Coke & Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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