BJR Corp. v. Commissioner
United States Tax Court
1. Held, since petitioner failed to prove that the taxpayer's return for the taxable period ending May 31, 1970, was filed more than 3 years prior to the issuance of the deficiency notice herein, such notice was timely.
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1. Held, since petitioner failed to prove that the taxpayer's return for the taxable period ending May 31, 1970, was filed more than 3 years prior to the issuance of the deficiency notice herein, such notice was timely. Sec. 6501(a), I.R.C. 1954. 2. Held, payments actually received by the taxpayer during the taxable period ending May 31, 1970, constituted rents for the use of mobile homes -- rather than capital advances or loans as contended by petitioner -- and since such rents were received without restriction as to their use, they were reportable in full for that period, notwithstanding…
1Opinion of the Court
BJR Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
BJR Corp. v. Commissioner
Docket No. 3358-75
United States Tax Court
67 T.C. 111; 1976 U.S. Tax Ct. LEXIS 33;
November 2, 1976, Filed
Decision will be entered under Rule 155.
1. Held, since petitioner failed to prove that the taxpayer's return for the taxable period ending May 31, 1970, was filed more than 3 years prior to the issuance of the deficiency notice herein, such notice was timely. Sec. 6501(a), I.R.C. 1954.
2. Held, payments actually received by the taxpayer during the taxable period ending May 31, 1970,…
2Cases cited42 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Sanford v. CommissionerUnited States Tax Court · 1968
- Brown v. HelveringSupreme Court of the United States · 1934
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
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