Citizens Mut. Inv. Asso. v. Commissioner
United States Board of Tax Appeals
The respondent determined a deficiency in income tax, under Title I of the Revenue Act of 1936, and a deficiency in personal holding company surtax, under Title IA. The taxes are imposed by separate titles and are different for purposes of the Board's jurisdiction.
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The respondent determined a deficiency in income tax, under Title I of the Revenue Act of 1936, and a deficiency in personal holding company surtax, under Title IA. The taxes are imposed by separate titles and are different for purposes of the Board's jurisdiction. Held, the petition filed timely in this proceeding alleging error with respect to the deficiency in the personal holding company surtax, only, does not give the Board jurisdiction over the deficiency in income tax, about which no allegations of error were made, so that an amendment to the petition filed after the ninety-day period,…
1Opinion of the Court
OPINION.
HaReon :
On June 10, 1941, the respondent mailed to the petitioner a notice of deficiency for the fiscal year ended March 31, 1938. The notice sets forth that there is a deficiency in income tax in the amount of $1,300.11, and a deficiency in the surtax on petitioner, as a personal *49holding company, in the amount of $4,546.86, and a 25 percent penalty of $1,186.72.
On September 8, 1941, petitioner filed a petition with this Board. In the petition, petitioner set forth as its pleadings as follows:(1) That the taxes in controversy are personal holding company surtaxes for the fiscal year…
2Cited by13 opinions
- Brooks v. CommissionerUnited States Tax Court · 1975
- O'Neil v. CommissionerUnited States Tax Court · 1976
- Fletcher Plastics, Inc. v. CommissionerUnited States Tax Court · 1975
- Tempest Assoc., Ltd. v. CommissionerUnited States Tax Court · 1990
- Bruno v. CommissionerUnited States Tax Court · 1979
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