Legal Opinion
John W. Harrison v. Commissioner of Internal Revenue, Clifford F. Harrison v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided August 8, 1956No. 19-2492PublishedCited by 7 opinions
1Opinion of the Court
JOHNSEN, Circuit Judge.
Deficiency assessments by the Commissioner of Internal Revenue against two taxpayers, for the calendar year 1947, were upheld by the Tax Court, 24 T.C. 46 and each of the taxpayers has petitioned for review.
The first contention made by petitioners is that the exchange transaction, on which the assessments were predicated, occurred in 1946, and not in 1947, so that any liability which they might have had on account thereof, as an “omission from gross income”, was barred by not .having been asserted against them, under .§ 275 (c) of the Internal Revenue Code of 1939, 26…
2Cases cited8 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Lloyd-Smith v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1941
- Neville Coke & Chemical Co. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1945
- National Weeklies v. Com'r of Internal RevenueCourt of Appeals for the Eighth Circuit · 1943
- Harrison v. CommissionerUnited States Tax Court · 1955
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Brown v. CommissionerUnited States Tax Court · 1956
- Rufus F. And Marguerite H. Turner v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1962
- Brown v. CommissionerUnited States Tax Court · 1956
- Portage Plastics Company, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1972
- Portage Plastics Company, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1972
2 more not listed; retrieve them via the Exa API.