Romine v. Comm'r
United States Tax Court
1. On December 8, 1949, petitioner and respondent executed consent agreements (Form 872) which provided that taxes due under petitioner's 1945 and 1946 returns might be assessed at any time on or before June 30, 1951. With respect to 1945, this consent was executed more than 3 but less than 5 years after the return for that year was filed. The consent with respect to 1946 was executed within 3 years after the 1946 return was filed.
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1. On December 8, 1949, petitioner and respondent executed consent agreements (Form 872) which provided that taxes due under petitioner's 1945 and 1946 returns might be assessed at any time on or before June 30, 1951. With respect to 1945, this consent was executed more than 3 but less than 5 years after the return for that year was filed. The consent with respect to 1946 was executed within 3 years after the 1946 return was filed. Additional consents to extend the time of assessment under either return to June 30, 1953, were subsequently executed by the parties. The statutory notice of…
1Opinion of the Court
Ralph Romine, Petitioner, v. Commissioner of Internal Revenue, Respondent
Romine v. Comm'r
Docket No. 49090
United States Tax Court
25 T.C. 859; 1956 U.S. Tax Ct. LEXIS 287;
January 26, 1956, Filed
Decision will be entered under Rule 50.
1. On December 8, 1949, petitioner and respondent executed consent agreements (Form 872) which provided that taxes due under petitioner's 1945 and 1946 returns might be assessed at any time on or before June 30, 1951. With respect to 1945, this consent was executed more than 3 but less than 5 years after the return for that year was filed. The consent with respect…
2Cases cited28 opinions
- Halle v. CommissionerUnited States Tax Court · 1946
- Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Avery v. CommissionerSupreme Court of the United States · 1934
- Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
- Towers v. CommissionerUnited States Tax Court · 1955
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