Helvering v. Wiese

MUNGER, District Judge.

This petition seeks to review a decision by the United States Board of Tax Appeals. The Commissioner had determined a deficiency income tax against the respondent for each of the years 1922 and 1923. Upon a review by the Board of Tax Appeals it was held that there was no deficiency for these years. In its decision the Board of Tax Appeals said:

“The only error assigned by the petitioner is that the statute of limitations had expired with respect to 1922 and 1923. The returns for 1922 and 1923 were filed on March 15, 1923, and March 13, 1924, respectively. Notice of…