John Wanamaker Philadelphia v. Commissioner
United States Board of Tax Appeals
The taxpayer filed a return for its fiscal year ended January 31, 1921, on June 10, 1921. After the enactment of the Revenue Act of 1921, on May 11, 1922, it filed a second return for the fiscal year ended January 31, 1921, which showed a larger tax due than was shown on the earlier return. Held, that the statute of limitations started to operate from the date of the filing of the second return and not from June 10, 1921, the date of the filing of the first return.
1Opinion of the Court
*865OPINION.
Smith:
It is the contention of the petitioner that the statute of limitations with respect to the determination of a deficiency for the fiscal year ended January 31, 1921, began to run on June 10, 1921, the date when its return for that fiscal year was filed in accordance with the provisions of the Bevenue Act of 1918 and regulations issued thereunder by the Commissioner with the approval of the Secretary of the Treasury; that the applicable statute of limitations is the four-year period prescribed by section 250(d) of the Bevenue Act of 1921; that the deficiency letter was not mailed…
2Cited by8 opinions
- John Wanamaker Philadlephia, Inc. v. United StatesUnited States Court of Claims · 1966
- A. Harris & Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Fred T. Ley & Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- John Wanamaker Philadelphia v. CommissionerUnited States Board of Tax Appeals · 1927
- Myles Salt Co. v. CommissionerUnited States Board of Tax Appeals · 1930
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