J. Friedman & Co. v. Commissioner
United States Board of Tax Appeals
1. The statute of limitation did not bar the assessment in March, 1926, of additional taxes for the year 1920 where returns were not shown to have been filed more than five years before the date of the assessment. 2. The Commissioner's determination that the four petitioners were affiliated for 1920 and 1921 approved.
1Opinion of the Court
*1121OPINION.
MuRdock:
The petitioner contends that the assessments for the year 1920 were made too late. It will be noted that these assessments were made in March, 1926. On February 26, 1926, the Revenue Act of 1926, was approved. It provided in section 277 (a) (3):
Tile amount of income, excess-profits, and war-profits taxes imposed by the Act entitled “An Act to provide revenue, equalize duties, and encourage the industries of the United States, and for other purposes,” approved August 5, 1909, the Act entitled “An Act to reduce tariff duties and to provide revenue for the Government, and for…
2Cases cited1 opinion
- E. I. Dupont De Nemours & Co. v. DavisSupreme Court of the United States · 1924
3Cited by6 opinions
- McCarthy Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1935
- Brodsky v. CommissionerUnited States Tax Court · 1962
- Hotel Equities Corp. v. CommissionerUnited States Tax Court · 1975
- Hotel Equities Corp. v. CommissionerUnited States Tax Court · 1975
- J. Friedman & Co. v. CommissionerUnited States Board of Tax Appeals · 1929
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