Legal Opinion

Continental Products Co. v. Commissioner

United States Board of Tax Appeals

Decided September 15, 1930No. Docket Nos. 5057, 20050, 21842, 28733Published

1. Affiliation denied. 2. Assessment and/or collection of taxes for the years 1918, 1919, and 1920 held not barred by the statute of limitations. 3. The Board is without power to adjudicate whether the circumstances upon which the Commissioner acted were such as to denote that the assessment or collection of the deficiency would be jeopardized by delay.

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1. Affiliation denied. 2. Assessment and/or collection of taxes for the years 1918, 1919, and 1920 held not barred by the statute of limitations. 3. The Board is without power to adjudicate whether the circumstances upon which the Commissioner acted were such as to denote that the assessment or collection of the deficiency would be jeopardized by delay. Veeder v. Commissioner, 36 Fed.(2d) 342. 4. The petitioner's objections to the validity of section 274(d) of the Revenue Act of 1921 are not sustained.

1Opinion of the Court

CONTINENTAL PRODUCTS CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Continental Products Co. v. Commissioner

Docket Nos. 5057, 20050, 21842, 28733.

United States Board of Tax Appeals

20 B.T.A. 818; 1930 BTA LEXIS 2031;

September 15, 1930, Promulgated

1. Affiliation denied.

2. Assessment and/or collection of taxes for the years 1918, 1919, and 1920 held not barred by the statute of limitations.

3. The Board is without power to adjudicate whether the circumstances upon which the Commissioner acted were such as to denote that the assessment or collection of the deficiency would be…

2Cases cited18 opinions

  1. Den Ex Dem. Murray v. Hoboken Land & Improvement Co.Supreme Court of the United States · 1856
  2. Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
  3. Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
  4. Springer v. United StatesSupreme Court of the United States · 1881
  5. Bailey, Collector of Internal Revenue v. GeorgeSupreme Court of the United States · 1922

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