Continental Oil Co. v. Commissioner

*323OPINION.

Van Fossan:

The question of the validity of section 280 of the Revenue Act of 1926 has been disposed of by us in Henry Cappelini et al., 14 B. T. A. 1269 (cited in numerous subsequent decisions). See also Phillips v. Commissioner, 42 Fed. (2d) 177.

It is obvious that if the appropriate statutes of limitations bar the respondent there is no necessity to discuss the questions raised by the petitioner in allegations of error Nos. 2 and 3. For this reason *324we will consider first the allegation of the petitioner that such statutes bar the assessment and collection of the taxes proposed for…