Legal Opinion

Bruno v. Commissioner

United States Tax Court

Decided June 7, 1979No. Docket No. 4466-76Published

When this case was commenced, Ps elected to have it heard as a small tax case under sec. 7463, I.R.C. 1954. Subsequently, the Commissioner moved to have the case removed from such classification and to claim an increased deficiency. His motions were granted without objection.

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When this case was commenced, Ps elected to have it heard as a small tax case under sec. 7463, I.R.C. 1954. Subsequently, the Commissioner moved to have the case removed from such classification and to claim an increased deficiency. His motions were granted without objection. Later, Ps moved to strike the amendment to answer on the grounds that the additional deficiency was not claimed within the period of limitations and that the deficiency exceeded the limit applicable in small tax cases. Held, since the case is no longer subject to sec. 7463, the Commissioner is not barred from raising a…

1Opinion of the Court

Salvatore I. and Norma J. Bruno, Petitioners v. Commissioner of Internal Revenue, Respondent

Bruno v. Commissioner

Docket No. 4466-76

United States Tax Court

72 T.C. 443; 1979 U.S. Tax Ct. LEXIS 107;

June 7, 1979, Filed

When this case was commenced, Ps elected to have it heard as a small tax case under sec. 7463, I.R.C. 1954. Subsequently, the Commissioner moved to have the case removed from such classification and to claim an increased deficiency. His motions were granted without objection. Later, Ps moved to strike the amendment to answer on the grounds that the additional deficiency was not…

2Cases cited8 opinions

  1. Robert A. Henningsen, and Cross and R.A. And Margaret Henningsen v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1957
  2. Abraham Teitelbaum v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1965
  3. Miami Valley Coated Paper Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
  4. Citizens Mut. Inv. Asso. v. CommissionerUnited States Board of Tax Appeals · 1942
  5. Ticker Publishing Co. v. CommissionerUnited States Board of Tax Appeals · 1942

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