Robinson v. Commissioner
United States Tax Court
The respondent's action in disallowing a deduction from income for 1942 claimed on account of an alleged loss from the transaction involved herein, sustained.
1Opinion of the Court
OPINION.
Hill, Judge:
In their opening statement at the hearing and on brief petitioners contended that the determination of any deficiency in this proceeding is barred by the expiration of the period of limitation upon assessment and collection as provided by section 275 (a), Internal Revenue Code. The statute was sought to be invoked with reference to the $10,000 deduction claimed in 1942. Since this issue was not raised in either the original petitions or the amended petitions, the statute of limitations is unavailable to petitioners as a defense against any assessment and collection herein.…
2Cases cited2 opinions
- Carpenter v. CommissionerUnited States Tax Court · 1948
- Exchange State Bank v. CommissionerUnited States Tax Court · 1947
3Cited by32 opinions
- Unvert v. CommissionerUnited States Tax Court · 1979
- B. C. Cook & Sons, Inc. v. CommissionerUnited States Tax Court · 1972
- Estate of Letts v. CommissionerUnited States Tax Court · 1997
- Brown v. CommissionerUnited States Tax Court · 1955
- Freytag v. CommissionerUnited States Tax Court · 1998
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