Legal Opinion

Hodges v. Commissioner

United States Board of Tax Appeals

Decided December 10, 1928No. Docket No. 19083Published

STATUTE OF LIMITATIONS. - Where an assessment was made in 1919 within the five-year period of limitation provided for by section 250(d) of the Revenue Act of 1918, and the Revenue Act of 1924 was enacted prior to the expiration of an extension of that period under section 250(d) of the Revenue Act of 1921, held, that the Commissioner had six years from date of assessment within which to begin suit or other proceeding for the collection of the tax under section 278(d) of the…

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STATUTE OF LIMITATIONS. - Where an assessment was made in 1919 within the five-year period of limitation provided for by section 250(d) of the Revenue Act of 1918, and the Revenue Act of 1924 was enacted prior to the expiration of an extension of that period under section 250(d) of the Revenue Act of 1921, held, that the Commissioner had six years from date of assessment within which to begin suit or other proceeding for the collection of the tax under section 278(d) of the Revenue Act of 1924, under authority of Art Metal Works,9 B.T.A. 491. The said six-year collection period having been…

1Opinion of the Court

C. S. HODGES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hodges v. Commissioner

Docket No. 19083.

United States Board of Tax Appeals

14 B.T.A. 664; 1928 BTA LEXIS 2943;

December 10, 1928, Promulgated

STATUTE OF LIMITATIONS. - Where an assessment was made in 1919 within the five-year period of limitation provided for by section 250(d) of the Revenue Act of 1918, and the Revenue Act of 1924 was enacted prior to the expiration of an extension of that period under section 250(d) of the Revenue Act of 1921, held, that the Commissioner had six years from date of assessment within which…

2Cases cited2 opinions

  1. Art Metal Works v. CommissionerUnited States Board of Tax Appeals · 1927
  2. Hodges v. CommissionerUnited States Board of Tax Appeals · 1928

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