Phoenix Ins. Co. v. Commissioner
United States Board of Tax Appeals
Held, that the manner in which the petitioner claimed and was allowed a deduction for Federal income taxes was not misrepresentation of a material fact upon which a closing agreement, entered into pursuant to section 606 of the Revenue Act of 1928, might be disregarded for the purpose of imposing additional income tax liability for the taxable period covered by the agreement.
1Opinion of the Court
*294OPINION.
Seawell:
The closing agreement executed on March 7, 1929, relating to the total income tax liability of the petitioner and its subsidiaries for 1926, was entered into pursuant to section 606 of the Eevenue Act of 1928, which reads as follows:(a) Authorisation.' — Tbe Commissioner (or any officer or employee of the Bureau of Internal Eevenue, including the field service, authorized in writing by the Commissioner) is authorized to enter into an agreement in writing with any person relating to the liability of such person (or of the person or estate for whom he acts) in respect of any…
2Cited by8 opinions
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- H Graphics/Access, Ltd. Partnership v. CommissionerUnited States Tax Court · 1992
- Bennett v. CommissionerUnited States Tax Court · 1988
- Lowell v. CommissionerUnited States Board of Tax Appeals · 1934
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