Legal Opinion

South Penn Oil Co. v. Commissioner

United States Board of Tax Appeals

Decided October 8, 1930No. Docket No. 20785Published

1. Henry Cappellini et al.,14 B.T.A. 1269, followed. 2. The provisions of section 280 of the Revenue Act of 1926 are applicable as well to transferees who acquired assets of a taxpayer prior to the enactment of the statute as to those thereafter acquiring such assets. 3. Agreements extending the time within which taxes might be assessed, executed by the taxpayers, dissolved West Virginia corporations, before the statutory period of limitation expired, held valid and…

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1. Henry Cappellini et al.,14 B.T.A. 1269, followed. 2. The provisions of section 280 of the Revenue Act of 1926 are applicable as well to transferees who acquired assets of a taxpayer prior to the enactment of the statute as to those thereafter acquiring such assets. 3. Agreements extending the time within which taxes might be assessed, executed by the taxpayers, dissolved West Virginia corporations, before the statutory period of limitation expired, held valid and effective to extend the running of the statute. 4. Agreements purporting to extend the time within which taxes might be…

1Opinion of the Court

SOUTH PENN OIL CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

South Penn Oil Co. v. Commissioner

Docket No. 20785.

United States Board of Tax Appeals

20 B.T.A. 1180; 1930 BTA LEXIS 1957;

October 8, 1930, Promulgated

1. Henry Cappellini et al.,14 B.T.A. 1269, followed.

2. The provisions of section 280 of the Revenue Act of 1926 are applicable as well to transferees who acquired assets of a taxpayer prior to the enactment of the statute as to those thereafter acquiring such assets.

3. Agreements extending the time within which taxes might be assessed, executed by the taxpayers,…

2Cases cited2 opinions

  1. Cappellini v. CommissionerUnited States Board of Tax Appeals · 1929
  2. South Penn Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1930

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