Bunnel v. Commissioner
United States Tax Court
Petitioners and their wholly owned corporation, which had in effect an election under subchap. S of the Code during 2 of the 3 years in issue, were in the business of dealing in oil leases. Respondent's notices of deficiencies for the 2 years in which the election was in effect were based in part on adjustments to the income of the corporation. Held, the notices of deficiency were valid notwithstanding the fact that such notices were not mailed to the corporation.
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Petitioners and their wholly owned corporation, which had in effect an election under subchap. S of the Code during 2 of the 3 years in issue, were in the business of dealing in oil leases. Respondent's notices of deficiencies for the 2 years in which the election was in effect were based in part on adjustments to the income of the corporation. Held, the notices of deficiency were valid notwithstanding the fact that such notices were not mailed to the corporation. Held, further, that the oil leases which petitioners and the corporation sold were property held for the sale to customers in the…
1Opinion of the Court
Robert L. Bunnel, Petitioner v. Commissioner of Internal Revenue, Respondent; Robert L. Bunnel and Vola V. Bunnel, Petitioners v. Commissioner of Internal Revenue, Respondent
Bunnel v. Commissioner
Docket Nos. 5373-66, 5374-66
United States Tax Court
50 T.C. 837; 1968 U.S. Tax Ct. LEXIS 75;
September 9, 1968, Filed
Decisions will be entered under Rule 50.
Petitioners and their wholly owned corporation, which had in effect an election under subchap. S of the Code during 2 of the 3 years in issue, were in the business of dealing in oil leases. Respondent's notices of deficiencies for the 2 years in…
2Cases cited11 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Courtney v. CommissionerUnited States Tax Court · 1957
- Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Olsen v. HelveringCourt of Appeals for the Second Circuit · 1937
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