Legal Opinion

Epstein v. Commissioner

United States Tax Court

Decided December 21, 1951No. Docket Nos. 29976, 29977Published

De factoConnecticut corporation held capable through its president of executing valid waivers in advance of expiration of statute of limitations so as to authorize respondent to send notices of liability to transferees within one year of expiration of statute as so extended.

1Opinion of the Court

Helen Epstein, Petitioner, v. Commissioner of Internal Revenue, Respondent. Max Epstein, Petitioner, v. Commissioner of Internal Revenue, Respondent

Epstein v. Commissioner

Docket Nos. 29976, 29977

United States Tax Court

17 T.C. 1034; 1951 U.S. Tax Ct. LEXIS 8;

December 21, 1951, Promulgated

Decisions will be entered for the respondent.

De factoConnecticut corporation held capable through its president of executing valid waivers in advance of expiration of statute of limitations so as to authorize respondent to send notices of liability to transferees within one year of expiration of statute as so…

2Cases cited16 opinions

  1. Galdi v. JonesCourt of Appeals for the Second Circuit · 1944
  2. Commissioner of Internal Revenue v. Angier CorporationCourt of Appeals for the First Circuit · 1931
  3. United States v. KruegerCourt of Appeals for the Third Circuit · 1941
  4. New York, Bridgeport & Eastern Railway Co. v. MotilSupreme Court of Connecticut · 1908
  5. Sharp v. Eagle Lake Lumber Co.California Court of Appeal · 1923

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