Reynolds Metals Co. v. State Tax Commission

The issue is one of statutory construction. The defendant Commission assessed additional corporation excise taxes against the plaintiff taxpayer for the years 1954 and 1955. ① The taxpayer contends that the Commission is barred from making such assessments because they were not timely made. The Tax Court held for the Commission and the taxpayer appeals. 2 OTR Adv Sh 349 (1966).

In November of 1956 the Commission notified the taxpayer of a proposed assessment of additional taxes. In December of 1956 the taxpayer paid a portion of the proposed additional assessment and declined to pay the…