Sanderling, Inc. v. Commissioner
United States Tax Court
Respondent issued a notice of deficiency to petitioner covering petitioner's taxable year ended Feb. 28, 1969. Respondent subsequently conceded that petitioner was liquidated and dissolved as a corporation on Jan. 22, 1969, and that its taxable year ended on that date.
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Respondent issued a notice of deficiency to petitioner covering petitioner's taxable year ended Feb. 28, 1969. Respondent subsequently conceded that petitioner was liquidated and dissolved as a corporation on Jan. 22, 1969, and that its taxable year ended on that date. Approximately 3 years after petitioner was dissolved, petitioner's treasurer (who was also a trustee in dissolution for the benefit of petitioner's stockholders and creditors) signed a consent as such trustee to extend the statute of limitations (Form 872). A later consent was signed by a certified public accountant acting…
1Opinion of the Court
Forrester, Judge:
Respondent has determined the following deficiencies in petitioner’s income tax plus additions to tax under sections 6651(a)1 and 6653(a):
Taxable year Deficiency Addition to Addition to tax under tax under sec. 6651(a) sec. 6653(a)
3/1/68 — 2/28/69 $7,231.81 $361.59 $361.59
3/1/69-12/31/69 3,619.03 904.76 180.95
1/1/71-4/16/71 62,698.34 15,674.59 3,134.92
Concessions having been made, the issues presented for our decision are as follows:(1) Whether this Court lacks jurisdiction in the instant case because the notice of deficiency upon which the petition herein is based was issued…
2Cases cited27 opinions
- Squire v. CapoemanSupreme Court of the United States · 1956
- Logan Lumber Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Tauber v. CommissionerUnited States Tax Court · 1955
- Shomaker v. CommissionerUnited States Tax Court · 1962
22 more not listed; retrieve them via the Exa API.
3Cited by62 opinions
- Achiro v. CommissionerUnited States Tax Court · 1981
- Estate of Emerson v. CommissionerUnited States Tax Court · 1977
- Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
- Estate of Brimm v. CommissionerUnited States Tax Court · 1978
- Mecom v. CommissionerUnited States Tax Court · 1993
57 more not listed; retrieve them via the Exa API.