Legal Opinion

Iba v. Commissioner

United States Board of Tax Appeals

Decided July 11, 1930No. Docket Nos. 32101, 32102PublishedCited by 4 opinions

In the absence of evidence as to when, if at all, income-tax returns were filed by the taxpayers, the Board can not determine whether assessment and collection of the proposed deficiencies are barred by the statute of limitations.

1Opinion of the Court

MEMORANDUM OPINION.

McMahon:

These are proceedings, duly consolidated for hearing and decision, for the redetermination of asserted deficiencies in income taxes for the years and in the amounts as follows:

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Each petition contains the allegation that the respondent’s determination of the deficiency was based upon the following errors:(1) Applying improper and inconsistent methods of accounting in respect of income and deductions, resulting in overstatement of income and the inclusion of income of other years than 1920.(2) In declaring the deficiency and proposing assessment of the…

2Cited by4 opinions

  1. Continental Products Co. v. CommissionerUnited States Board of Tax Appeals · 1930
  2. Emerson v. CommissionerUnited States Board of Tax Appeals · 1937
  3. Iba v. CommissionerUnited States Board of Tax Appeals · 1930
  4. Stages v. CommissionerUnited States Tax Court · 1961

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