French & Co. v. Commissioner
United States Board of Tax Appeals
1. The Board has no jurisdiction to redetermine the tax liability for a year for which the Commissioner has determined no deficiency, the only action of the Commissioner being the rejection of claims for refund of taxes already paid. 2. Where the Superintendent of Banks of the State of Oregon had taken possession of the assets of a State bank for the purpose of liquidation, held, not to be such a receivership as will deprive the Board, under section 282(a) of the Revenue Act…
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1. The Board has no jurisdiction to redetermine the tax liability for a year for which the Commissioner has determined no deficiency, the only action of the Commissioner being the rejection of claims for refund of taxes already paid. 2. Where the Superintendent of Banks of the State of Oregon had taken possession of the assets of a State bank for the purpose of liquidation, held, not to be such a receivership as will deprive the Board, under section 282(a) of the Revenue Act of 1926, of jurisdiction of a proceeding brought before it subsequent to the action of such superintendent. Under such…
1Opinion of the Court
FRENCH & COMPANY (BANKERS), IN LIQUIDATION UNDER FRANK C. BRAMWELL, SUPERINTENDENT OF BANKS OF THE STATE OF OREGON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
French & Co. v. Commissioner
Docket No. 15061.
United States Board of Tax Appeals
10 B.T.A. 665; 1928 BTA LEXIS 4045;
February 13, 1928, Promulgated
1. The Board has no jurisdiction to redetermine the tax liability for a year for which the Commissioner has determined no deficiency, the only action of the Commissioner being the rejection of claims for refund of taxes already paid.
2. Where the Superintendent of Banks of the…
2Cases cited2 opinions
- Frelinghuysen v. BaldwinDistrict Court, D. New Jersey · 1882
- French & Co. v. CommissionerUnited States Board of Tax Appeals · 1928