Legal Opinion

Art Metal Works v. Commissioner

United States Board of Tax Appeals

Decided December 6, 1927No. Docket No. 16226Published

Where an assessment was made in 1921, within the five-year period of limitation provided by section 250(d) of the Act of 1921, and the Revenue Act of 1924 was enacted prior to the expiration of that five-year period, respondent has six years from the date of the assessment within which to begin a suit or other proceeding for the collection of such tax, under section 278(d) of the Revenue Act of 1924. Collection held not barred.

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Where an assessment was made in 1921, within the five-year period of limitation provided by section 250(d) of the Act of 1921, and the Revenue Act of 1924 was enacted prior to the expiration of that five-year period, respondent has six years from the date of the assessment within which to begin a suit or other proceeding for the collection of such tax, under section 278(d) of the Revenue Act of 1924. Collection held not barred. Reliance Manufacturing Co.,7 B.T.A. 583, overruled.

1Opinion of the Court

ART METAL WORKS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Art Metal Works v. Commissioner

Docket No. 16226.

United States Board of Tax Appeals

9 B.T.A. 491; 1927 BTA LEXIS 2576;

December 6, 1927, Promulgated

Where an assessment was made in 1921, within the five-year period of limitation provided by section 250(d) of the Act of 1921, and the Revenue Act of 1924 was enacted prior to the expiration of that five-year period, respondent has six years from the date of the assessment within which to begin a suit or other proceeding for the collection of such tax, under section 278(d)…

2Cases cited2 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

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