Reliance Mfg. Co. v. Commissioner
United States Board of Tax Appeals
1. JURISDICTION. - Under the provisions of section 283(f) of the Revenue Act of 1926, the Board has jurisdiction in a case in which a jeopardy assessment was made in February, 1924, and a claim for abatement was made, considered, and finally rejected on July 30, 1925. 2. STATUTE OF LIMITATIONS. - Where tentative return, Form 1031-T, was filed on March 13, 1919, and the return, Form 1120, as required by law, was filed on June 16, 1919, held, that the 5-year period of…
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1. JURISDICTION. - Under the provisions of section 283(f) of the Revenue Act of 1926, the Board has jurisdiction in a case in which a jeopardy assessment was made in February, 1924, and a claim for abatement was made, considered, and finally rejected on July 30, 1925. 2. STATUTE OF LIMITATIONS. - Where tentative return, Form 1031-T, was filed on March 13, 1919, and the return, Form 1120, as required by law, was filed on June 16, 1919, held, that the 5-year period of limitation provided by section 250(d) of the Revenue Act of 1921, began to run at midnight, June 16, 1919, under authority of…
1Opinion of the Court
*585OPINION.
Tkussell:
The Board has jurisdiction of this proceeding under the provisions of section 283(f) of the Revenue Act of 1926. See Appeal of William A. Slater Mills, Inc., 5 B. T. A. 971, and Appeal of Nice Ball Bearing Co., 5 B. T. A. 484.
The petitioner’s income and excess-profits tax return for the year 1918, Form 1129, filed on June 16, 1919, was the return required*by law and the five-year period of limitation, within which assessment may be made or a suit or proceeding begun for the collection of such taxes, as provided by section 250 (d) of the Revenue Acts of 1918 and 1921, began to…
2Cases cited2 opinions
- Bowers v. New York & Albany Lighterage Co.Supreme Court of the United States · 1927
- United States v. St. Louis, San Francisco & Texas Railway Co.Supreme Court of the United States · 1926
3Cited by3 opinions
- Art Metal Works v. CommissionerUnited States Board of Tax Appeals · 1927
- Reliance Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Walker v. CommissionerUnited States Board of Tax Appeals · 1933