Legal Opinion
Commissioner v. Northern Coal Co.
Court of Appeals for the First Circuit
Decided January 3, 1933No. Nos. 2716, 2717PublishedCited by 2 opinions
1Opinion of the Court
WILSON, Circuit Judge.
Those cases are before this court on petitions for review of a decision of the Board of Tax Appeals. They were argued together before this court, and as the issues involved are the same, they may be disposed of in one opinion.
A consolidated return for the tax year of 1920 by six affiliated corporations, including the respondents in these two cases, was filed on April 12, 1921. The five-year period under the Revenue Act of 1921 (42 Stat. 227) for assessing and collecting any deficiency tax for the year 1920, therefore, expired on April 12, 1926, unless extended by waiver.
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2Cases cited23 opinions
- Gould v. GouldSupreme Court of the United States · 1917
- Graham & Foster v. GoodcellSupreme Court of the United States · 1931
- Stange v. United StatesSupreme Court of the United States · 1931
- Bowers v. New York & Albany Lighterage Co.Supreme Court of the United States · 1927
- United States v. Heinszen & Co.Supreme Court of the United States · 1907
18 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Hamilton Web Co. v. PageDistrict Court, D. Rhode Island · 1934
- Helvering v. WieseCourt of Appeals for the Eighth Circuit · 1934