Legal Opinion

Marix v. Commissioner

United States Tax Court

Decided December 12, 1950No. Docket Nos. 18859, 18864-18868, 18880Published

1. Under section 311 (b) (1), I. R. C., the Commissioner has one year after the expiration of the period of limitation for assessment of taxes against the taxpayer within which to proceed against a transferee of the taxpayer's assets, and the provisions of section 311 (b) (1) are applicable notwithstanding that the period of limitation against the taxpayer is computed under section 275 (b), I. R. C. 2. Stockholders, who were distributees of assets of a dissolved corporation…

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1. Under section 311 (b) (1), I. R. C., the Commissioner has one year after the expiration of the period of limitation for assessment of taxes against the taxpayer within which to proceed against a transferee of the taxpayer's assets, and the provisions of section 311 (b) (1) are applicable notwithstanding that the period of limitation against the taxpayer is computed under section 275 (b), I. R. C. 2. Stockholders, who were distributees of assets of a dissolved corporation which had complied with requirements of section 275 (b), held liable as transferees for deficiencies in excess profits…

1Opinion of the Court

Estate of Arthur T. Marix, Deceased, Ralph D. Sweeney, Executor, Petitioner, et al., 1 v. Commissioner of Internal Revenue, Respondent

Marix v. Commissioner

Docket Nos. 18859, 18864-18868, 18880

United States Tax Court

15 T.C. 819; 1950 U.S. Tax Ct. LEXIS 23;

December 12, 1950, Promulgated

Decision will be entered for the respondent.

1. Under section 311 (b) (1), I. R. C., the Commissioner has one year after the expiration of the period of limitation for assessment of taxes against the taxpayer within which to proceed against a transferee of the taxpayer's assets, and the provisions of section 311…

2Cases cited2 opinions

  1. Marix v. CommissionerUnited States Tax Court · 1950
  2. Cage v. CommissionerUnited States Tax Court · 1950

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