Neal v. Commissioner
United States Board of Tax Appeals
Where in 1920 the Commissioner made a specific ruling that taxpayer was a trust, taxable as such, and sent personal written notice of such ruling to taxpayer, the ruling was not reversed or revoked by various court decisions, departmental rulings or interpretations general in character. Such a ruling was not revoked prior to the receipt by taxpayer of a specific notice of revocation in 1927.
1Opinion of the Court
J. HENRY NEAL, EDMUND C. CAMPBELL, WILLIAM F. KENNEY, WILLIAM R. SAMPSON, WILLIAM H. HITCHCOCK, TRUSTEES OF THE FIRST PEOPLES TRUST, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Neal v. Commissioner
Docket No. 45403.
United States Board of Tax Appeals
26 B.T.A. 551; 1932 BTA LEXIS 1291;
June 29, 1932, Promulgated
Where in 1920 the Commissioner made a specific ruling that taxpayer was a trust, taxable as such, and sent personal written notice of such ruling to taxpayer, the ruling was not reversed or revoked by various court decisions, departmental rulings or interpretations general…
2Cases cited3 opinions
- Hecht v. MalleySupreme Court of the United States · 1924
- Shuey v. United StatesSupreme Court of the United States · 1876
- Van Cleave Trust v. CommissionerUnited States Board of Tax Appeals · 1929