Michigan Iron & Land Co. v. United States

WHALEY, Judge.

The case presents the questions whether, where the Commissioner of Internal Revenue has granted a special assessment of profit taxes pursuant to sections 327 and 328 of the Revenue Act of 1918 (40 Stat. 1093), a court may in an action for a refund review the Commissioner’s determination of the taxpayer’s net income, and (2) whether, if such power of review exists, the Commissioner properly valued the taxpayer’s real property holdings as of March 1, 1913.

The plaintiff is a Michigan corporation and possessed large timber and land holdings which had buen acquired before the income…