Legal Opinion

Steele v. Commissioner

United States Board of Tax Appeals

Decided March 20, 1936No. Docket No. 73347Published

Taxpayer is not estopped to deny liability in 1931 on income realized in 1923 where a representative of the respondent was fully apprised of the facts and both the taxpayer and respondent's representative relied on a ruling of the respondent's office to the effect that the transaction resulted in no income in 1923.

1Opinion of the Court

ESTATE OF WILLIAM STEELE, JOSEPH M. STEELE, TRUSTEE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Steele v. Commissioner

Docket No. 73347.

United States Board of Tax Appeals

34 B.T.A. 173; 1936 BTA LEXIS 741;

March 20, 1936, Promulgated

Taxpayer is not estopped to deny liability in 1931 on income realized in 1923 where a representative of the respondent was fully apprised of the facts and both the taxpayer and respondent's representative relied on a ruling of the respondent's office to the effect that the transaction resulted in no income in 1923.

A. E. James, Esq., and D. Hays…

2Cases cited8 opinions

  1. R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
  2. Helvering v. SalvageSupreme Court of the United States · 1936
  3. Tide Water Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Union Metal Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1925
  5. Sugar Creek Coal & Mining Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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