Legal Opinion

Central Outdoor Advertising Co. v. Commissioner

United States Tax Court

Decided June 11, 1954No. Docket No. 42346Published

Excess Profits Tax -- Sec. 722, I. R. C. -- Applications for Relief -- Period of Limitations -- Secs. 722 (d) and 322 (b) (4), I. R. C. -- The period of limitation on the filing of applications for relief under section 722 for years beginning prior to December 31, 1941, begins with the date the return or the payment relied upon was due rather than the earlier date upon which the return was filed and the tax was paid.

1Opinion of the Court

Central Outdoor Advertising Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Central Outdoor Advertising Co. v. Commissioner

Docket No. 42346

United States Tax Court

22 T.C. 549; 1954 U.S. Tax Ct. LEXIS 184;

June 11, 1954, Filed June 11, 1954, Filed

Decision will be entered pursuant to paragraph 11 of the stipulation.

Excess Profits Tax -- Sec. 722, I. R. C. -- Applications for Relief -- Period of Limitations -- Secs. 722 (d) and 322 (b) (4), I. R. C. -- The period of limitation on the filing of applications for relief under section 722 for years beginning prior to December…

2Cases cited2 opinions

  1. Allsen v. South Atlantic S. S. Co.Court of Appeals for the Fifth Circuit · 1949
  2. Central Outdoor Advertising Co. v. CommissionerUnited States Tax Court · 1954

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