Crosman v. Commissioner
United States Board of Tax Appeals
A corporation filed its return for 1919 on March 15, 1920, and prior to the expiration of the five-year period for making assessments on account thereof a waiver was filed which extended the period for assessment to December 31, 1925. On September 29, 1925, a deficiency notice was mailed to the corporation and on February 21, 1927, notices were mailed to the petitioners, advising them of their liability under section 280 of the Revenue Act of 1926 as transferees of the…
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A corporation filed its return for 1919 on March 15, 1920, and prior to the expiration of the five-year period for making assessments on account thereof a waiver was filed which extended the period for assessment to December 31, 1925. On September 29, 1925, a deficiency notice was mailed to the corporation and on February 21, 1927, notices were mailed to the petitioners, advising them of their liability under section 280 of the Revenue Act of 1926 as transferees of the aforesaid corporation. Held, that the assessment of the additional tax of the corporation against the petitioners is not…
1Opinion of the Court
*392OPINION.
Seawell:
The errors assigned by the petitioners with respect to the constitutionality of section 280 of the Revenue Act of 1926 are admitted by them to have been heretofore disposed of by the Board adversely to their position, though they do not admit the correctness of those decisions. Henry Cappellini et al., 14 B. T. A. 1269; Grand Rapids National Bank, 15 B. T. A. 1166; Annie G. Phillips et al., Executors, 15 B. T. A. 1218; affd., Phillips v. Commissioner, 42 Fed. (2d) 177; and Woodley Petroleum Co. et al., 16 B. T. A. 253.
The remaining issue is whether the statute of limitations…
2Cited by6 opinions
- Buzard v. CommissionerUnited States Board of Tax Appeals · 1933
- Morning Sun Publishing Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Buzard v. CommissionerUnited States Board of Tax Appeals · 1933
- Crosman v. CommissionerUnited States Board of Tax Appeals · 1931
- Miller v. CommissionerUnited States Tax Court · 1975
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