Old Farmers Oil Co. v. Commissioner
United States Board of Tax Appeals
(1) Section 277(b) of the Revenue Act of 1924 applied. (2) An erroneous decision of a question of law made by an officer of the Government is not binding on his successor in office.
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(1) Section 277(b) of the Revenue Act of 1924 applied. (2) An erroneous decision of a question of law made by an officer of the Government is not binding on his successor in office. (3) Where a vendor executes a contract of sale and a deed and where the vendee is immediately placed in possession of the property sold, and where the contract and deed are placed in escrow the deed to be delivered when he has paid the purchase price, held that such transaction was completed in the year in which the contract and deed were executed. (4) Certain obligations payable to petitioner held not to have a…
1Opinion of the Court
*213OPINION.
Milliken:
There is no merit in the plea of the statute of limitations. Petitioner filed its return for 1919 on March 10, 1920; respondent mailed the deficiency letter involved in this proceeding on February 6, 1925, and petitioner filed its petition with the Board on March 26, 1925. The five year period within which assessment can be made, provided in section 277 (a) (2) of the Revenue Act of 1924, is extended by subdivision (b) of the same section. This subdivision provides:(b) Tbe period within which an assessment is required to be made by subdivision (a) of this section in respect…
2Cases cited1 opinion
- Loud v. Pomona Land & Water Co.Supreme Court of the United States · 1894
3Cited by5 opinions
- Continental Oil Co. v. JonesCourt of Appeals for the Tenth Circuit · 1949
- Commissioner of Internal Revenue v. AmbroseCourt of Appeals for the Fifth Circuit · 1942
- T. K. Harris Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
- Old Farmers Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- St. Marys Oil & Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1940