Biggers v. Commissioner
United States Board of Tax Appeals
Petitioners filed a joint tentative return for the year 1934 on March 15, 1935, on forms supplied by the Commissioner through the local collector, and secured an extension of time to file their final return. A new regulation, article 117-5, Regulations 86, construed section 117 of the Revenue Act of 1934, effecting a change in the treatment of capital gains and losses, in its specific application to husband and wife.
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Petitioners filed a joint tentative return for the year 1934 on March 15, 1935, on forms supplied by the Commissioner through the local collector, and secured an extension of time to file their final return. A new regulation, article 117-5, Regulations 86, construed section 117 of the Revenue Act of 1934, effecting a change in the treatment of capital gains and losses, in its specific application to husband and wife. Petitioners, in fact, had no knowledge of that regulation when the tentative return was filed. Regulations 86 were released to the public on March 2, 1935. After March 15, 1935,…
1Opinion of the Court
JOHN D. BIGGERS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
MARY I. BIGGERS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Biggers v. Commissioner
Docket Nos. 89465, 89466.
United States Board of Tax Appeals
39 B.T.A. 480; 1939 BTA LEXIS 1024;
February 24, 1939, Promulgated
Petitioners filed a joint tentative return for the year 1934 on March 15, 1935, on forms supplied by the Commissioner through the local collector, and secured an extension of time to file their final return. A new regulation, article 117-5, Regulations 86, construed section 117 of the Revenue Act…
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- Sutton v. United StatesSupreme Court of the United States · 1921
- Wilber Nat. Bank of Oneonta v. United StatesSupreme Court of the United States · 1935
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