Western Shade Cloth Co. v. United States

LITTLETON, Judge.

We are unable to agree with the contention of the plaintiff that a determination and computation of a tax liability by the commissioner’s office and the mailing of a letter showing the results thereof constitute an assessment of the tax as that term "is used in the revenue statutes for the purpose of computing the statutory period of limitation within which the commissioner may assess and collect a tax, or adjust the tax liability of a taxpayer for the purpose of allowing or rejecting claims for abatement, credit, or refund. The limitation for making assessments is suspended…