Chesapeake & Virginian Coal Co. v. Commissioner
United States Board of Tax Appeals
The petitioner filed its income and profits-tax return for the calendar year 1918 on June 16, 1919. On February 6, 1924, the petitioner and the Commissioner executed a consent pursuant to the provisions of section 250(d) of the Revenue Act of 1921, whereby the petitioner consented to a determination, assessment, and collection of the amount of income, excess-profits, and war-profits taxes for the year 1918, the consent to remain in effect for a period of one year after the…
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The petitioner filed its income and profits-tax return for the calendar year 1918 on June 16, 1919. On February 6, 1924, the petitioner and the Commissioner executed a consent pursuant to the provisions of section 250(d) of the Revenue Act of 1921, whereby the petitioner consented to a determination, assessment, and collection of the amount of income, excess-profits, and war-profits taxes for the year 1918, the consent to remain in effect for a period of one year after the expiration of such statutory period as extended by consents already on file in the Commissioner's office. This consent…
1Opinion of the Court
*1053OPINION.
Smith :
In this proceeding the petitioner contends that the consent filed by it on June 6, 1925, did not provide for an extension of the time within which the Commissioner might institute suits or proceedings to collect an additional tax for 1918; that at the time the deficiency notice was mailed on December 2, 1925, the time within which suits' or proceedings might have been instituted to secure the collection of the taxes had long since expired; and that no consent at the time within which suits or proceedings for the collection of those taxes could be instituted had been executed by…
2Cases cited1 opinion
- Russell v. United StatesSupreme Court of the United States · 1929
3Cited by1 opinion
- Chesapeake & Virginian Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1929