Legal Opinion

Wisconsin Farmer Co. v. Commissioner

United States Board of Tax Appeals

Decided January 20, 1942No. Docket No. 105917Published

Immediately prior to the taxable year petitioner was notified by state taxing authorities that it owed additional state income taxes for prior taxable years. Petitioner protested assessment of such additional taxes on the ground that a statute of limitations had run with respect to some of the years and, furthermore, contended that petitioner had paid the correct taxes for all the years in question.

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Immediately prior to the taxable year petitioner was notified by state taxing authorities that it owed additional state income taxes for prior taxable years. Petitioner protested assessment of such additional taxes on the ground that a statute of limitations had run with respect to some of the years and, furthermore, contended that petitioner had paid the correct taxes for all the years in question. In the taxable year the state legislature passed a law nullifying the effect of the statute of limitations upon which petitioner relied as a bar to the action of the state taxing authorities with…

1Opinion of the Court

WISCONSIN FARMER COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Wisconsin Farmer Co. v. Commissioner

Docket No. 105917.

United States Board of Tax Appeals

46 B.T.A. 116; 1942 BTA LEXIS 906;

January 20, 1942, Promulgated

Immediately prior to the taxable year petitioner was notified by state taxing authorities that it owed additional state income taxes for prior taxable years. Petitioner protested assessment of such additional taxes on the ground that a statute of limitations had run with respect to some of the years and, furthermore, contended that petitioner had paid the…

2Cases cited9 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. United States v. One 1936 Model Ford V-8 De Luxe Coach, Commercial Credit Co.Supreme Court of the United States · 1939
  3. Eingartner v. Illinois Steel Co.Wisconsin Supreme Court · 1899
  4. State ex rel. Globe Steel Tubes Co. v. LyonsWisconsin Supreme Court · 1924
  5. Banking Commission v. BuchananWisconsin Supreme Court · 1938

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