Walker v. Commissioner
United States Board of Tax Appeals
1. Statute of limitations had tolled deficiency asserted at Docket No. 20409 when notice of deficiency was issued. 2. Earnings and profits of a corporation accrued after March 1, 1913, must be combined with operating losses sustained during the same period in order to determine the amount of earnings and profits accumulated after March 1, 1913, which may be distributed to stockholders subject to surtaxes.
1Opinion of the Court
OPINION.
Lansdon :
At Docket No. 20407 the respondent asserts deficiencies in income tax against petitioner Talbot C. Walker for the years 1917,1918,1919 and 1920, in the respective amounts of $68.87, $30.97, $8,679.76 and $2,033.41. At Docket No. 20409 the tax in controversy is $46,488.05, which is the unabated remainder of an original deficiency asserted against W. H. Talbot for the year 1919, in the amount of $154,663.09. At Docket No. 20411, the tax in controversy is $22,402.98, which is the unabated remainder of an original deficiency asserted against the estate of Frederick C. Talbot for…
2Cases cited11 opinions
- Southern Pacific Co. v. LoweSupreme Court of the United States · 1918
- Lynch v. HornbySupreme Court of the United States · 1918
- Russell v. United StatesSupreme Court of the United States · 1929
- Lynch v. TurrishSupreme Court of the United States · 1918
- Lamden v. SharpTennessee Supreme Court · 1847
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3Cited by1 opinion
- Walker v. CommissionerUnited States Board of Tax Appeals · 1933