Michael v. Commissioner of Internal Revenue

CHASE, Circuit Judge.

The petitioners invoked the jurisdiction of the Board of Tax Appeals on January 17, 1927, to review a determination of the Commissioner of Internal Revenue of a deficiency in income taxes for the year 1922 against the Buffalo Realty Corporation. The corporation had been completely liquidated at the time the additional tax was determined. The liability of the petitioners for the payment of the tax as transferees was asserted. No question of the jurisdiction of the Board of Tax Appeals was involved.

While the appeal was pending before the Board, and before hearing on the…