Schmalstig v. Commissioner
United States Board of Tax Appeals
A letter written to the executors of an estate, advising that their claim for refund of estate taxes is rejected in its entirety, is not a notice of deficiency within the purview of section 308(a) of the Revenue Act of 1926 as amended by section 501 of the Revenue Act of 1934.
1Opinion of the Court
ESTATE OF CHARLES SCHMALSTIG, DECEASED, JULIUS M. SCHMALSTIG AND CHARLES F. BLUM, EXECUTORS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Schmalstig v. Commissioner
Docket No. 103584.
United States Board of Tax Appeals
43 B.T.A. 433; 1941 BTA LEXIS 1505;
January 28, 1941, Promulgated
A letter written to the executors of an estate, advising that their claim for refund of estate taxes is rejected in its entirety, is not a notice of deficiency within the purview of section 308(a) of the Revenue Act of 1926 as amended by section 501 of the Revenue Act of 1934.
Murray Seasongood, Esq.,…
2Cases cited14 opinions
- United States v. Chemical Foundation, Inc.Supreme Court of the United States · 1926
- Oswego Falls Corp. v. CommissionerUnited States Board of Tax Appeals · 1932
- Cornelius Cotton Mills v. CommissionerUnited States Board of Tax Appeals · 1926
- Greve v. CommissionerUnited States Board of Tax Appeals · 1938
- John A. Gebelein, Inc. v. CommissionerUnited States Board of Tax Appeals · 1938
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