Landau v. Commissioner
United States Tax Court
Upon the facts held that section 3801 is not applicable to lift the bar of section 275 (a), Internal Revenue Code. James Brennen, 20 T. C. 495; Max Schulman, 21 T. C. 403, followed.
1Opinion of the Court
OPINION.
Hakron, Judge:
The deficiency in each proceeding for 1946 results from adjustments made by the respondent on April 29, 1952, the date on which each deficiency notice was mailed. The determinations of deficiencies for 1946 on April 29, 1952, are barred by the statute of limitations unless section 3801, Internal Revenue Code, applies, as the respondent contends. Petitioners contend that section 8801 does not apply. They rely upon James Brennen, 20 T. C. 495.
The facts having been stipulated, it is unnecessary to restate the facts. In the Brennen case, the facts were the same. We pointed…
2Cases cited6 opinions
- Neuberger v. CommissionerSupreme Court of the United States · 1940
- Switzer v. CommissionerUnited States Tax Court · 1953
- Randolph Products Co. v. ManningCourt of Appeals for the Third Circuit · 1949
- Brennen v. CommissionerUnited States Tax Court · 1953
- Jennings v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1940
1 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- United States v. Erma RosenbergerCourt of Appeals for the Eighth Circuit · 1956
- Gooding v. United StatesUnited States Court of Claims · 1964
- Harlan v. Comm'rUnited States Tax Court · 2001
- Lazarus v. United StatesUnited States Court of Claims · 1956
- Robert Azevedo, Irene Kershaw, and Paul Kershaw, J. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
7 more not listed; retrieve them via the Exa API.