Legal Opinion

Joseph Garneau Co. v. Commissioner

United States Board of Tax Appeals

Decided November 21, 1924No. Docket No. 40PublishedCited by 4 opinions

The Board has jurisdiction over an appeal involving a deficiency in tax determined by the Commissioner subsequent to the passage of the Revenue Act of 1924.

1Opinion of the Court

*77OPINION.

James: Whether the Board has jurisdiction of this case depends upon the construction of section 250 of the Eevenue Act of 1921, and sections 274, 280, and 288 of the Eevenue Act of 1924.

We have already determined in the Appeal of Everett Knitting Works, 1 B. T. A. 5, that this Board has no jurisdiction to entertain an appeal in any case in which the deficiency in tax was determined, assessed, and paid prior to the date of the enactment of the Eevenue Act of 1924. In so deciding, the Board held:

The Board was created to give the taxpayer a chance to have an open and neutral…

2Cited by4 opinions

  1. Foundation Co. v. United StatesUnited States Court of Claims · 1936
  2. J. S. Hoskins Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  3. Miami Metals Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  4. Smith v. CommissionerUnited States Board of Tax Appeals · 1926

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