Legal Opinion

Oakdale Coal Co. v. Commissioner

United States Board of Tax Appeals

Decided March 16, 1925No. Docket No. 1252Published

Where no notice of deficiency is sent under subdivision (a) of section 274 of the Revenue Act of 1924, but only a notice is sent of assessment under subdivision (d) of that section, appeal will not lie until the taxpayer is notified of the Commissioner's action on a proper claim in abatement.

1Opinion of the Court

Appeal of OAKDALE COAL CO.

Oakdale Coal Co. v. Commissioner

Docket No. 1252.

United States Board of Tax Appeals

1 B.T.A. 773; 1925 BTA LEXIS 2811;

March 16, 1925, decided Submitted February 18, 1925.

Where no notice of deficiency is sent under subdivision (a) of section 274 of the Revenue Act of 1924, but only a notice is sent of assessment under subdivision (d) of that section, appeal will not lie until the taxpayer is notified of the Commissioner's action on a proper claim in abatement.

Addison S. Pratt, Esq., for the taxpayer.

George K. Bowden, Esq., for the Commissioner.

STERNHAGEN

Before JAMES,…

2Cases cited1 opinion

  1. Oakdale Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1925

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