Matteawan Mfg. Co. v. Commissioner
United States Board of Tax Appeals
1. A letter dated August 10, 1925, from the Commissioner of Internal Revenue, advising petitioner that its claim for abatement of assessments made on its tax return for the year 1918 had been both allowed and rejected in part and asserting new deficiencies accordingly, is such a determination of a deficiency by the Commissioner after June 2, 1924, as to give the Board jurisdiction to hear and determine an appeal therefrom. Appeal of Matteawan Mfg.
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1. A letter dated August 10, 1925, from the Commissioner of Internal Revenue, advising petitioner that its claim for abatement of assessments made on its tax return for the year 1918 had been both allowed and rejected in part and asserting new deficiencies accordingly, is such a determination of a deficiency by the Commissioner after June 2, 1924, as to give the Board jurisdiction to hear and determine an appeal therefrom. Appeal of Matteawan Mfg. Co.,4 B.T.A. 953. 2. The consolidated return of two corporations, though affiliation be later denied, will remain the return of each corporation…
1Opinion of the Court
*791OPINION.
Lansdon:
In our settlement of the issues of this proceeding we must determine: (1) Which, if any, of the letters addressed by the Commissioner to the petitioner is a deficiency notice under the provisions of section 279 of the Revenue Act of 1924, and (2) the nature, effect, and authority of and for the assessment made on October 6, 1919, whether such assessment ivas based on a return required by law, and if so, whether its collection is barred by the five-year period of limitation then in force, or is governed by the six-year period provided by the Revenue Act of 1924.
In denying the…
2Cited by1 opinion
- Matteawan Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1928