Bateman v. Commissioner
United States Board of Tax Appeals
1. Where taxpayer signed a waiver after the expiration of the statutory period of limitations and claims that the signed such waiver under a mistake due to lack of knowledge that such period had expired, held such waiver is valid in the absence of clear and satisfactory proof of such mistake and in the absence of evidence showing that his counsel, upon whose advice he signed such waiver, was ignorant of the facts or his rights, knowledge of counsel being imputable to his…
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1. Where taxpayer signed a waiver after the expiration of the statutory period of limitations and claims that the signed such waiver under a mistake due to lack of knowledge that such period had expired, held such waiver is valid in the absence of clear and satisfactory proof of such mistake and in the absence of evidence showing that his counsel, upon whose advice he signed such waiver, was ignorant of the facts or his rights, knowledge of counsel being imputable to his client. 2. Where a waiver, unlimited as to time, was signed by taxpayer and notice of deficiency was mailed about four and…
1Opinion of the Court
OPINION.
McMahon :
This is a proceeding for the redetermination of' deficiencies in income tax as follows:
1918_$20,019.98
1919_ 14, 911.70
1920__ 26, 295. 02
It is admitted by the respondent that he erred in the computation of the deficiencies for 1918 and 1919 in crediting as taxes previously assessed and paid the amounts of $4,797.49 and $5,014.70, respectively, whereas there should have been credited the amounts of $15,520.18 and $14,563.38, respectively. Crediting such amounts to the total tax liability of petitioner as computed by respondent, the deficiencies now claimed by respondent for the…
2Cases cited13 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Bull v. United StatesSupreme Court of the United States · 1935
- Burnet v. ClarkSupreme Court of the United States · 1932
- Buck v. KuykendallSupreme Court of the United States · 1925
- Dalton v. BowersSupreme Court of the United States · 1932
8 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Wilkinson v. CommissionerUnited States Tax Court · 1979
- Hatfield v. CommissionerUnited States Tax Court · 1977
- Roberts v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
- McManus v. CommissionerUnited States Tax Court · 1975
- Krueger v. CommissionerUnited States Tax Court · 1967
13 more not listed; retrieve them via the Exa API.