Legal Opinion
Colony, Inc. v. Commissioner
Supreme Court of the United States
Decided June 9, 1958No. 306PublishedCited by 222 opinions
1Opinion of the CourtJustice Harlan
The sole question in this case is whether assessments by the Commissioner of two asserted tax deficiencies were barred by the three-year statute of limitations provided in the Internal Revenue Code of 1939.
Under the 1939 Code the general statute of limitations governing the assessment of federal income tax deficiencies is fixed at three years from the date on which the taxpayer filed his return, § 275 (a), 53 Stat. 86, except in cases involving a fraudulent return or failure to file a return, where a tax may be assessed at any time. § 276 (a), 53 Stat. 87. A special five-year period of…
2Cases cited16 opinions
- DeGanay v. LedererSupreme Court of the United States · 1919
- Reis v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1944
- Colony, Inc. v. CommissionerUnited States Tax Court · 1956
- The Colony, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1957
- Uptegrove Lumber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
11 more not listed; retrieve them via the Exa API.
3Cited by222 opinions
- Durovic v. CommissionerUnited States Tax Court · 1970
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Schirmer v. CommissionerUnited States Tax Court · 1987
- United States v. Home Concrete & Supply, LLCSupreme Court of the United States · 2012
- Aldon Homes, Inc. v. CommissionerUnited States Tax Court · 1959
217 more not listed; retrieve them via the Exa API.