Legal Opinion

Estate of J. B. Williams v. Commissioner

United States Tax Court

Decided July 15, 1953No. Docket Nos. 27414, 37690Unpublished

1. Held, deficiencies determined by the respondent are barred by statute of limitations in the absence of proof of fraud or the execution of consent agreements extending the period prescribed by the statute of limitations. 2. Held, deficiency and negligence penalty approved for year upon which the statute of limitations was not pleaded.

1Opinion of the Court

Estate of J. B. Williams, Deceased, Tommy J. Williams and Charles J. Williams, Administrators, and Rosa Williams v. Commissioner.

Estate of J. B. Williams v. Commissioner

Docket Nos. 27414, 37690.

United States Tax Court

1953 Tax Ct. Memo LEXIS 173; 12 T.C.M. (CCH) 829; T.C.M. (RIA) 53251;

July 15, 1953

1. Held, deficiencies determined by the respondent are barred by statute of limitations in the absence of proof of fraud or the execution of consent agreements extending the period prescribed by the statute of limitations.

2. Held, deficiency and negligence penalty approved for year upon which the…

2Cases cited3 opinions

  1. Farmers Feed Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  2. Bonwit Teller & Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  3. Concrete Engineering Co. v. CommissionerUnited States Board of Tax Appeals · 1930

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