Legal Opinion

National Tank & Export Co. v. Commissioner

United States Board of Tax Appeals

Decided April 16, 1926No. Docket No. 3274Published

JURISDICTION. - Under section 279 of the Revenue Act of 1924, the Board is without jurisdiction to hear and determine an appeal from a jeopardy assessment prior to the rejection of a claim for abatement.

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JURISDICTION. - Under section 279 of the Revenue Act of 1924, the Board is without jurisdiction to hear and determine an appeal from a jeopardy assessment prior to the rejection of a claim for abatement. Following Appeal of Oakdale Coal Co.,1 B.T.A. 773. STATUTE OF LIMITATIONS. - A consolidated return for two or more corporations, made in accordance with sections 239 and 240(a) of the Revenue Act of 1918, is the return required by law of each of the corporations whose net income and deductions are included therein. The period of limitation provided by section 277(a)(2) of the Revenue Act of…

1Opinion of the Court

APPEAL OF NATIONAL TANK & EXPORT CO.

National Tank & Export Co. v. Commissioner

Docket No. 3274.

United States Board of Tax Appeals

3 B.T.A. 1217; 1926 BTA LEXIS 2440;

April 16, 1926, Decided Submitted July 7, 1925.

JURISDICTION. - Under section 279 of the Revenue Act of 1924, the Board is without jurisdiction to hear and determine an appeal from a jeopardy assessment prior to the rejection of a claim for abatement. Following Appeal of Oakdale Coal Co.,1 B.T.A. 773.

STATUTE OF LIMITATIONS. - A consolidated return for two or more corporations, made in accordance with sections 239 and 240(a) of the…

2Cases cited3 opinions

  1. F. A. Hall Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  2. National Tank & Export Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  3. Oakdale Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1925

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