Legal Opinion

Reliance Mfg. Co. v. Commissioner

United States Board of Tax Appeals

Decided June 28, 1927No. Docket No. 6021PublishedCited by 3 opinions

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

  1. Bowers v. New York & Albany Lighterage Co.Supreme Court of the United States · 1927
  2. United States v. St. Louis, San Francisco & Texas Railway Co.Supreme Court of the United States · 1926

3Cited by3 opinions

  1. Art Metal Works v. CommissionerUnited States Board of Tax Appeals · 1927
  2. Reliance Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1927
  3. Walker v. CommissionerUnited States Board of Tax Appeals · 1933

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