Legal Opinion

Bellevue Mfg. Co. v. Commissioner

United States Tax Court

Decided June 10, 1957No. Docket No. 39437Unpublished

Held, in the absence of any books and records by the petitioner, the respondent was correct in determining petitioner's income on the cash receipts and disbursements method; held, further, the petitioner did not show reasonable cause for failure to file proper corporate income tax returns for the years here involved and consequently is liable for additions to tax under section 291(a); held, further, the statute of limitations is inapplicable to any of the taxable years…

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Held, in the absence of any books and records by the petitioner, the respondent was correct in determining petitioner's income on the cash receipts and disbursements method; held, further, the petitioner did not show reasonable cause for failure to file proper corporate income tax returns for the years here involved and consequently is liable for additions to tax under section 291(a); held, further, the statute of limitations is inapplicable to any of the taxable years involved.

1Opinion of the Court

Bellevue Manufacturing Co. v. Commissioner.

Bellevue Mfg. Co. v. Commissioner

Docket No. 39437.

United States Tax Court

T.C. Memo 1957-94; 1957 Tax Ct. Memo LEXIS 156; 16 T.C.M. (CCH) 390; T.C.M. (RIA) 57094;

June 10, 1957

Held, in the absence of any books and records by the petitioner, the respondent was correct in determining petitioner's income on the cash receipts and disbursements method; held, further, the petitioner did not show reasonable cause for failure to file proper corporate income tax returns for the years here involved and consequently is liable for additions to tax under section…

2Cases cited12 opinions

  1. Lucas v. Pilliod Lumber Co.Supreme Court of the United States · 1930
  2. Aluminum Castings Co. v. RoutzahnSupreme Court of the United States · 1930
  3. SoRelle v. CommissionerUnited States Tax Court · 1954
  4. Hartley v. CommissionerUnited States Tax Court · 1954
  5. Consolidated Apparel Co. v. CommissionerUnited States Tax Court · 1952

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