Epstein v. Commissioner
United States Tax Court
De factoConnecticut corporation held capable through its president of executing valid waivers in advance of expiration of statute of limitations so as to authorize respondent to send notices of liability to transferees within one year of expiration of statute as so extended.
1Opinion of the Court
OPINION.
Oppeh, Judge:
If the statute of limitations expired as to petitioners’ transferor less than a year prior to the determination of liability against petitioners, the notice was timely and petitioners are con-cededly liable as transferees. Section 311 (b), Internal Revenue Code, The answer to this question depends in turn upon whether two waivers executed ostensibly on behalf of the corporate transferor were valid. ■ The three years constituting the original statutory period of limitation had not expired on January 11, 1946. A waiver executed on behalf of the Corporation by its president…
2Cases cited15 opinions
- Galdi v. JonesCourt of Appeals for the Second Circuit · 1944
- Commissioner of Internal Revenue v. Angier CorporationCourt of Appeals for the First Circuit · 1931
- United States v. KruegerCourt of Appeals for the Third Circuit · 1941
- New York, Bridgeport & Eastern Railway Co. v. MotilSupreme Court of Connecticut · 1908
- Sharp v. Eagle Lake Lumber Co.California Court of Appeal · 1923
10 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
- Field v. CommissionerUnited States Tax Court · 1959
- Epstein v. CommissionerUnited States Tax Court · 1951
- Field v. CommissionerUnited States Tax Court · 1959
- Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
1 more not listed; retrieve them via the Exa API.