Wrightsman Petroleum Co. v. United States

WHITAKER, Judge.

This case presents two questions: (1) whether the plaintiff is entitled on the merits to certain deductions for depletion; and (2) whether a claim therefor was filed in time. We think it necessary to discuss only the latter question.

Plaintiff is the parent of the Osage Oil Corporation, against which, on August' 17, 1928, the Commissioner of Internal Revenue asserted a deficiency for the year 1926 in the amount of $17,170.87. The plaintiff admitted that that company was liable for additional taxes in the amount of $1,713.-53, but denied liability for the balance. On May 27,…