Legal Opinion

Bankers Trust Co. v. Commissioner

United States Board of Tax Appeals

Decided September 11, 1931No. Docket No. 32459PublishedCited by 11 opinions

The provisions of section 202(a)(2) of the Revenue Act of 1921 are not applicable to a valid and continuing trust taxable under section 219 of the same act.

1Opinion of the Court

*12OPINION.

GOODRICH:

Before considering this case upon its merits, let us dispose of two preliminary issues raised by petitioner. By amendment to its petition and by motion to dismiss petitioner challenges the jurisdiction of the Board, objecting to the misnomer in the deficiency notice and asserting that, because of his failure to address said notice to petitioner under its correct name and address, respondent has not complied with the statutory requirements in that regard. We attach no importance to this complaint. Petitioner was not misled by this misnomer. It is not alleged that the notice…

2Cases cited2 opinions

  1. May v. HeinerSupreme Court of the United States · 1930
  2. Taft v. BowersSupreme Court of the United States · 1929

3Cited by11 opinions

  1. Lifter v. CommissionerUnited States Tax Court · 1973
  2. Clodfelter v. CommissionerUnited States Tax Court · 1971
  3. Commissioner of Internal Revenue v. RosenheimCourt of Appeals for the Third Circuit · 1942
  4. Scruggs v. CommissionerUnited States Board of Tax Appeals · 1934
  5. Russell v. BowersDistrict Court, S.D. New York · 1939

6 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API