Kohlhase v. Commissioner
United States Tax Court
Statute of Limitations -- Request for Prompt Assessment -- Section 275 (b). -- A letter asking for an early determination of income tax liability held not a request within section 275 (b) limiting the assessment period for income, excess profits, and declared value excess profits taxes to 18 months.
1Opinion of the Court
OPINION.
MuRdock, eJudge:
Section 311 (b) (1) of the Internal Revenue Code provides that the period of limitation for assessment of the liability of an initial transferee of the property of a taxpayer shall be “within one year after the expiration of the period of limitation for assessment against the taxpayer.” Section 275 (a) provides the general rule that taxes shall be assessed within 3 years after the return was filed, and no proceeding for collection without assessment shall be begun after the expiration of such period. The transferee notices were mailed about 3 years and 2 months after…
2Cited by7 opinions
- Kohlhase v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1950
- Cage v. CommissionerUnited States Tax Court · 1950
- Koufman v. CommissionerUnited States Tax Court · 1976
- Cage v. CommissionerUnited States Tax Court · 1950
- Kohlhase v. CommissionerUnited States Tax Court · 1949
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