Legal Opinion

A. J. Crowhurst & Sons, Inc. v. Commissioner

United States Board of Tax Appeals

Decided October 28, 1938No. Docket No. 83788Published

Petitioner filed capital stock tax return containing a declaration of value of corporate stock as the net worth of the corporation. Prior to expiration of extensions granted under regulations, another declaration was filed.

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Petitioner filed capital stock tax return containing a declaration of value of corporate stock as the net worth of the corporation. Prior to expiration of extensions granted under regulations, another declaration was filed. Held, that under section 215(d) and (f), National Industrial Recovery Act of 1933, no amendment of return is permitted; held, further, that ignorance or mistake as to nature and extent of petitioner's rights under the statute does not relieve the taxpayer on the theory of mistaken election; held, further, that section 215(d) and (f) of the National Industrial Recovery Act…

1Opinion of the Court

A. J. CROWHURST & SONS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

A. J. Crowhurst & Sons, Inc. v. Commissioner

Docket No. 83788.

United States Board of Tax Appeals

38 B.T.A. 1072; 1938 BTA LEXIS 795;

October 28, 1938, Promulgated

Petitioner filed capital stock tax return containing a declaration of value of corporate stock as the net worth of the corporation. Prior to expiration of extensions granted under regulations, another declaration was filed. Held, that under section 215(d) and (f), National Industrial Recovery Act of 1933, no amendment of return is permitted; held,…

2Cases cited4 opinions

  1. O'Shaughnessy v. CommissionerUnited States Board of Tax Appeals · 1930
  2. William A. Webster Co. v. CommissionerUnited States Board of Tax Appeals · 1938
  3. Haggar Co. v. CommissionerUnited States Board of Tax Appeals · 1938
  4. A. J. Crowhurst & Sons, Inc. v. CommissionerUnited States Board of Tax Appeals · 1938

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