Hollie v. Commissioner
United States Tax Court
Subsequent to a termination assessment for the period Jan. 1, 1973, to Nov. 12, 1973, respondent collected funds belonging to petitioner in an amount in excess of the amount for which, the parties now agree, petitioner is liable for Federal income taxes and additions to tax for the full taxable year 1973. Held, refund of the amount by which the funds collected by respondent as a result of the termination assessment exceed petitioner's tax liability for the year 1973, as…
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Subsequent to a termination assessment for the period Jan. 1, 1973, to Nov. 12, 1973, respondent collected funds belonging to petitioner in an amount in excess of the amount for which, the parties now agree, petitioner is liable for Federal income taxes and additions to tax for the full taxable year 1973. Held, refund of the amount by which the funds collected by respondent as a result of the termination assessment exceed petitioner's tax liability for the year 1973, as agreed upon by the parties, is barred by the expiration of the statutory periods of limitation ( sec. 6512(b)(2), I.R.C.…
1Opinion of the Court
Willie Lee Hollie, Petitioner v. Commissioner of Internal Revenue, Respondent
Hollie v. Commissioner
Docket No. 11027-76
United States Tax Court
73 T.C. 1198; 1980 U.S. Tax Ct. LEXIS 161;
March 26, 1980, Filed
Decision will be entered under Rule 155.
Subsequent to a termination assessment for the period Jan. 1, 1973, to Nov. 12, 1973, respondent collected funds belonging to petitioner in an amount in excess of the amount for which, the parties now agree, petitioner is liable for Federal income taxes and additions to tax for the full taxable year 1973. Held, refund of the amount by which the funds…
2Cases cited43 opinions
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- United States v. Memphis Cotton Oil Co.Supreme Court of the United States · 1933
- United States v. Felt & Tarrant Manufacturing Co.Supreme Court of the United States · 1931
- United States v. KalesSupreme Court of the United States · 1941
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