City Baking Co. v. Commissioner
United States Board of Tax Appeals
Where an assessment was made in 1921 within the five-year period of limitation provided by section 250(d) of the Revenue Act of 1921, and the Revenue Act of 1924 was enacted prior to the expiration of that five-year period, respondent has six years from the date of assessment within which to begin a suit or other proceeding for the collection of such tax under section 278(d) of the Revenue Act of 1924. Collection held not barred.
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Where an assessment was made in 1921 within the five-year period of limitation provided by section 250(d) of the Revenue Act of 1921, and the Revenue Act of 1924 was enacted prior to the expiration of that five-year period, respondent has six years from the date of assessment within which to begin a suit or other proceeding for the collection of such tax under section 278(d) of the Revenue Act of 1924. Collection held not barred. Art Metal Works v. Commissioner,9 B.T.A. 491, followed.
1Opinion of the Court
CITY BAKING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
City Baking Co. v. Commissioner
Docket No. 10707.
United States Board of Tax Appeals
10 B.T.A. 593; 1928 BTA LEXIS 4076;
February 7, 1928, Promulgated
Where an assessment was made in 1921 within the five-year period of limitation provided by section 250(d) of the Revenue Act of 1921, and the Revenue Act of 1924 was enacted prior to the expiration of that five-year period, respondent has six years from the date of assessment within which to begin a suit or other proceeding for the collection of such tax under section…
2Cases cited2 opinions
- Art Metal Works v. CommissionerUnited States Board of Tax Appeals · 1927
- City Baking Co. v. CommissionerUnited States Board of Tax Appeals · 1928