Lawrence v. Commissioner
United States Tax Court
1. Statute of Limitations -- Sec. 275 (c) -- 25 Per Cent Omission From Gross Income -- Omission Explained in Return. -- The 5-year period of limitations provided by section 275 (c) applies where a taxpayer omitted from gross income shown on the return a capital gain, which omission represented more than 25 per cent of the gross income shown on the return.
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1. Statute of Limitations -- Sec. 275 (c) -- 25 Per Cent Omission From Gross Income -- Omission Explained in Return. -- The 5-year period of limitations provided by section 275 (c) applies where a taxpayer omitted from gross income shown on the return a capital gain, which omission represented more than 25 per cent of the gross income shown on the return. It is immaterial that the omission was explained on a separate sheet of paper attached to the return. 2. Statute of Limitations -- Sec. 275 (c) -- Sec. 275 (e). -- The 5-year period of section 275 (c) is applicable even though the omitted…
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined a deficiency of $2,931.14 in the income tax of the petitioners for 1948. The facts have been stipulated. The stipulation is adopted as the findings of fact.
The petitioners, husband and wife, filed a joint Federal income tax return for 1948 with the collector of internal revenue, Los Angeles, California, on May 31, 1949, an extension to that date for filing having been granted. The notice of deficiency was not mailed until May 10,1954, after the 3-year period, and after the 4-year period but before the 5-year period for assessment and…
2Cases cited54 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Reis v. CommissionerUnited States Tax Court · 1942
- Reis v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1944
- Colony, Inc. v. CommissionerUnited States Tax Court · 1956
- Green v. CommissionerUnited States Tax Court · 1946
49 more not listed; retrieve them via the Exa API.
3Cited by99 opinions
- Bokum v. CommissionerUnited States Tax Court · 1990
- Lardas v. CommissionerUnited States Tax Court · 1992
- Heman v. CommissionerUnited States Tax Court · 1959
- Golsen v. CommissionerUnited States Tax Court · 1970
- Swanson v. CommissionerUnited States Tax Court · 1996
94 more not listed; retrieve them via the Exa API.