Legal Opinion

Manson Western Corp. v. Commissioner

United States Tax Court

Decided June 30, 1981No. Docket No. 14010-79Published

Respondent notified petitioner that he intended to issue a notice of deficiency for the tax that sec. 531, I.R.C. 1954, imposes upon accumulated earnings. Before expiration of the period given petitioner to reply to respondent's notification, respondent issued a notice of deficiency.

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Respondent notified petitioner that he intended to issue a notice of deficiency for the tax that sec. 531, I.R.C. 1954, imposes upon accumulated earnings. Before expiration of the period given petitioner to reply to respondent's notification, respondent issued a notice of deficiency. Held, the burden of proof will be upon a petitioner unless it complies with the requirements of sec. 534(c), I.R.C. 1954, so long as it is apprised of the notice of deficiency any time before the notice of deficiency issues. Held, further, this petitioner's reasonable belief that the issuance of the notice of…

1Opinion of the Court

Manson Western Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

Manson Western Corp. v. Commissioner

Docket No. 14010-79

United States Tax Court

76 T.C. 1161; 1981 U.S. Tax Ct. LEXIS 106;

June 30, 1981, Filed

Respondent notified petitioner that he intended to issue a notice of deficiency for the tax that sec. 531, I.R.C. 1954, imposes upon accumulated earnings. Before expiration of the period given petitioner to reply to respondent's notification, respondent issued a notice of deficiency. Held, the burden of proof will be upon a petitioner unless it complies with the…

2Cases cited7 opinions

  1. Ned Miller and Frances Miller v. The United States of AmericaCourt of Appeals for the Second Circuit · 1974
  2. Corn Belt Hatcheries, Inc. v. CommissionerUnited States Tax Court · 1969
  3. Exchange and Savings Bank of Berlin v. United StatesDistrict Court, D. Maryland · 1964
  4. Manson Western Corp. v. CommissionerUnited States Tax Court · 1981
  5. Hicks Nurseries, Inc. v. CommissionerUnited States Tax Court · 1974

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