National Refining Co. v. Commissioner
United States Board of Tax Appeals
The Board has jurisdiction to determine whether or not an assessment of a deficiency in tax against a taxpayer is barred by the statute of limitations contained in section 250(d) of the Revenue Act of 1921 and section 277(a)(2) of the Revenue Act of 1924. The filing of an amended return does not toll the statutes of limitations contained in section 250(d) of the Revenue Act of 1921 and section 277(a)(2) of the Revenue Act of 1924.
1Opinion of the Court
*238OPINION.
Graupner :
On the hearing of this appeal, the taxpayer waived its claims as to one of the two alleged errors asserted in its petition and confined its presentation and argument to the following assigned error of the Commissioner in determining the tax:
That the entire additional assessment as proposed in department letter dated July 21, 1924, against all of the above-named companies for the taxable year 1917, is outlawed under the Statute of Limitations contained in section 277(a) (2) of the Revenue Act of 1924.
In his answer to the petition, the Commissioner, after admitting most of the…
2Cases cited6 opinions
- Amy v. WatertownSupreme Court of the United States · 1889
- Bennecke v. Insurance Co.Supreme Court of the United States · 1882
- California Southern Hotel Co. v. CallenderCalifornia Supreme Court · 1892
- Lehigh Valley R. Co. v. Providence Washington Ins.Court of Appeals for the Second Circuit · 1909
- Fairview R. R. v. SpillmanOregon Supreme Court · 1893
1 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Klemp v. CommissionerUnited States Tax Court · 1981
- Billings v. Comm'rUnited States Tax Court · 2006
- Billings v. Comm'rUnited States Tax Court · 2006
- Billings v. Comm'rUnited States Tax Court · 2006
- Cantrell & Cochrane v. CommissionerUnited States Board of Tax Appeals · 1930
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