Thorlight-Duncker Carpet Co. v. Commissioner
United States Board of Tax Appeals
1. STATUTE OF LIMITATIONS. - The statutory period for assessment is shown to have been extended by agreements in writing, consequently, the proposed deficiencies are not barred. Sections 278(c) of the Revenue Acts of 1924 and 1926, and sections 274(a) and 277(b) of the Revenue Act of 1926. 2. CHANGE OF ACCOUNTING PERIOD. - For many years prior to 1919 petitioner had kept its accounts and closed its books on a basis of calendar years.
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1. STATUTE OF LIMITATIONS. - The statutory period for assessment is shown to have been extended by agreements in writing, consequently, the proposed deficiencies are not barred. Sections 278(c) of the Revenue Acts of 1924 and 1926, and sections 274(a) and 277(b) of the Revenue Act of 1926. 2. CHANGE OF ACCOUNTING PERIOD. - For many years prior to 1919 petitioner had kept its accounts and closed its books on a basis of calendar years. It determined to change its system and on October 31, 1919, took its inventory and closed its accounts for the period of 10 months ending on that date. It failed…
1Opinion of the Court
*471OPINION.
Teussell :
The petitioner contends in the first issue that the assessment of the proposed deficiencies is barred by the statute of limitations. To the contrary, however, the evidence shows that the petitioner and the respondent, through agreements in writing effected as contemplated in sections 278 (c) of the Revenue Acts of 1924 and 1926, an extension of the periods of limitation and prior to the expiration of the periods agreed upon the respondent determined the deficiencies and mailed the deficiency letter to the petitioner so that the running of the statute of limitations is stayed…
2Cited by1 opinion
- Thorlight-Duncker Carpet Co. v. CommissionerUnited States Board of Tax Appeals · 1931