Legal Opinion

Gill v. Commissioner

United States Tax Court

Decided March 31, 1961No. Docket No. 84163Published

Judgment of United States District Court entered pursuant to remand by circuit court decision rendered July 18, 1958, in favor of petitioner requiring the exclusion from petitioner's 1949 income of amount previously reported on his income tax return, on theory that such amount was properly includible in petitioner's 1948 income, held to constitute circumstances falling within the provisions of sections 1311- 1314, I.R.C. 1954, reopening the statute of limitations for the…

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Judgment of United States District Court entered pursuant to remand by circuit court decision rendered July 18, 1958, in favor of petitioner requiring the exclusion from petitioner's 1949 income of amount previously reported on his income tax return, on theory that such amount was properly includible in petitioner's 1948 income, held to constitute circumstances falling within the provisions of sections 1311- 1314, I.R.C. 1954, reopening the statute of limitations for the limited adjustment permitted by those sections for a period not expiring earlier than 1 year from October 16, 1958, the…

1Opinion of the Court

Estate of Sara Louise Gill, Robert S. Gill, Executor and Robert S. Gill, Individually, Petitioners, v. Commissioner of Internal Revenue, Respondent

Gill v. Commissioner

Docket No. 84163

United States Tax Court

35 T.C. 1208; 1961 U.S. Tax Ct. LEXIS 190;

March 31, 1961, Filed

Decision will be entered for the respondent.

Judgment of United States District Court entered pursuant to remand by circuit court decision rendered July 18, 1958, in favor of petitioner requiring the exclusion from petitioner's 1949 income of amount previously reported on his income tax return, on theory that such amount was…

2Cases cited12 opinions

  1. Market Street Railway Co. v. Railroad Commission of CaliforniaSupreme Court of the United States · 1945
  2. Richfield Oil Corp. v. State Board of EqualizationSupreme Court of the United States · 1946
  3. Estate of SoRelle v. CommissionerUnited States Tax Court · 1958
  4. Priest Trust v. CommissionerUnited States Tax Court · 1946
  5. Ambassador Hotel Co. v. CommissionerUnited States Tax Court · 1959

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