Legal Opinion

Ennis v. Commissioner

United States Board of Tax Appeals

Decided November 21, 1930No. Docket Nos. 15281, 24961, 24962PublishedCited by 2 opinions

1. Caroline J. Shaw, Executrix,21 B.T.A. 400, followed. 2. The Board has no jurisdiction where a deficiency notice is sent to a corporation and a partnership files a petition.

1Opinion of the Court

OPINION.

Murdock :

These three proceedings were consolidated.

The Commissioner, by two letters each dated January 8,1927, notified Elias R. Ennis and Oscar M. Ennis, respectively, that under section 280 of the Revenue Act of 1926 he proposed to assess against Elias N. Ennis an amount of $670.79 and against Oscar M. Ennis an *407amount of $570.78, as their liability as transferees of the assets of “ E. N. & O. M. Ennis ” for unpaid income and profits taxes in the amount of $1,141.57 assessed against the corporation for the years 1917 and 1918. A corporation income-tax return for “ E. N. & O. M. Ennis…

2Cases cited3 opinions

  1. Bowers v. New York & Albany Lighterage Co.Supreme Court of the United States · 1927
  2. Russell v. United StatesSupreme Court of the United States · 1929
  3. United States v. UpdikeSupreme Court of the United States · 1930

3Cited by2 opinions

  1. Ennis v. CommissionerUnited States Board of Tax Appeals · 1930
  2. Newport Co. v. CommissionerUnited States Board of Tax Appeals · 1931

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