Sidles v. Commissioner
United States Tax Court
1. Statute of Limitations. -- Petitioner filed his final income tax return for 1947 on January 23, 1948, after obtaining an extension of time for filing from January 15, 1948, to February 1, 1948, and contends that the statute of limitations began to run on February 1, 1948. Respondent mailed a notice of deficiency on February 20, 1951. Held, statute of limitations began to run on March 15, 1948. 2. Community Property. -- Petitioner received a bonus in December 1947…
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1. Statute of Limitations. -- Petitioner filed his final income tax return for 1947 on January 23, 1948, after obtaining an extension of time for filing from January 15, 1948, to February 1, 1948, and contends that the statute of limitations began to run on February 1, 1948. Respondent mailed a notice of deficiency on February 20, 1951. Held, statute of limitations began to run on March 15, 1948. 2. Community Property. -- Petitioner received a bonus in December 1947 subsequent to the enactment of the community property law in the State of Nebraska on September 7, 1947. Petitioner apportioned…
1Opinion of the Court
OPINION.
Withey, Judge:
The first issue for decision is whether the respondent’s notice of deficiency was timely. Petitioner contends that he was required by law to file a final income tax return for 1947 by January 15, 1948, because his prior estimate of tax liability was seriously underestimated. He states that be obtained an extension of time for filing his final return until February 1, 1948; that he filed a final return on January 23,1948; and that therefore respondent was required to assess a deficiency by February 1, 1951; that respondent, having notified petitioner of a deficiency on…
2Cases cited6 opinions
- Varney v. . DitmarsNew York Court of Appeals · 1916
- Veit v. CommissionerUnited States Tax Court · 1947
- Wrightsman v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1940
- State v. American State BankNebraska Supreme Court · 1922
- Joseph Campbell Preserve Co. v. HolcombSupreme Court of Kansas · 1903
1 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Duval Motor Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Wilkerson v. CommissionerUnited States Tax Court · 1965
- Duval Motor Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Gajewski v. CommissionerUnited States Tax Court · 1985
- Monaghan v. CommissionerUnited States Tax Court · 1957
3 more not listed; retrieve them via the Exa API.