Cage v. Commissioner
United States Tax Court
A letter attached to and requesting an early examination of the final returns of a dissolved corporation, which was addressed to the Collector, and disclosed no corporate authority for the request, held not to constitute a request for prompt assessment within the meaning of section 275 (b) of the Internal Revenue Code.
1Opinion of the Court
OPINION.
Arundell, Judge:
Petitioners concede their liability as transferees for the deficiencies determined against the Central Oil Co. if the Commissioner is not barred from assessing such taxes by the provisions of sections 275 (b)1 and 3112 of the Internal Bevenue -Code.
The parties are agreed that the dissolution of Central was in good faith commenced and completed within 18 months after the letter in question was filed with the collector along with the corporate returns. The sole question is whether the letter attached to the final corporate returns constituted a request for prompt…
2Cases cited3 opinions
- Angelus Milling Co. v. CommissionerSupreme Court of the United States · 1945
- Lucas v. Pilliod Lumber Co.Supreme Court of the United States · 1930
- Kohlhase v. CommissionerUnited States Tax Court · 1949
3Cited by4 opinions
- Marix v. CommissionerUnited States Tax Court · 1950
- Cage v. CommissionerUnited States Tax Court · 1950
- Marix v. CommissionerUnited States Tax Court · 1950
- R. B. Griffith Co. v. CommissionerUnited States Tax Court · 1973