Legal Opinion

Fleitmann v. Commissioner

United States Board of Tax Appeals

Decided April 20, 1931No. Docket No. 28450PublishedCited by 1 opinion

Waivers executed by petitioner, to which the Commissioner's name was affixed by employees in the Bureau of Internal Revenue or in the office of the Collector at the direction of persons authorized by the Commissioner to sign his name, are valid and extend the statutory period.

1Opinion of the Court

*1225OPINION.

Arundell:

Petitioner’s return for 1918 was filed on March 13, 1919, and, unless the limitation period was waived, the time for assessment and collection expired five years later or on March 13, 1924. The assessment, a part of which the respondent is now attempting to collect, was timely, having been made on March 8, 1924. We have then, the precise question of whether collection is barred.

*1226The waivers filed by petitioner are as follows:

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Whether the first of these waivers was invalid by reason of the lack of respondent’s signature need not be decided, because the second…

2Cases cited10 opinions

  1. Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
  2. Stange v. United StatesSupreme Court of the United States · 1931
  3. United States v. MacDanielSupreme Court of the United States · 1833
  4. Burnet v. Chicago Railway Equipment Co.Supreme Court of the United States · 1931
  5. Aiken v. BurnetSupreme Court of the United States · 1931

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3Cited by1 opinion

  1. Fleitmann v. CommissionerUnited States Board of Tax Appeals · 1931

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