Ludwig Littauer & Co. v. Commissioner
United States Board of Tax Appeals
The Board has no jurisdiction of a proceeding to contest the Commissioner's notice, issued under section 146, Revenue Act of 1936, that the petitioner intended to hinder and prevent the collection of tax and that the amount covering a period of less than the taxable year had been assessed and was immediately due and payable.
1Opinion of the Court
OPINION.
Sternhagen :
The Commissioner has filed a motion to dismiss “for lack of jurisdiction in that no final determination of a deficiency has been made by the Commissioner and no notice of a deficiency has been sent by the Commissioner to the petitioner, as provided by section 272 of the Revenue Act of 1936.” Under date of August 21, 1937, he sent to the petitioner by registered mail a notice of his finding that the petitioner intended to hinder and prevent the collection of tax justly due for the period January 1 to August 21, 1937, and that, pursuant to the authority granted by section…
2Cases cited1 opinion
- Helvering v. Morgan's, Inc.Supreme Court of the United States · 1934
3Cited by18 opinions
- Schreck v. United StatesDistrict Court, D. Maryland · 1969
- Charles R. Rambo v. United States of America and District Director of Internal Revenue for the District of KentuckyCourt of Appeals for the Sixth Circuit · 1974
- Clark v. CampbellCourt of Appeals for the Fifth Circuit · 1974
- Rambo v. United StatesDistrict Court, W.D. Kentucky · 1972
- Irving v. GrayCourt of Appeals for the Second Circuit · 1973
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