Reliance Mfg. Co. v. Commissioner
United States Board of Tax Appeals
1. JURISDICTION. - Under the provisions of section 283(f) of the Revenue Act of 1926, the Board has jurisdiction in a case in which a jeopardy assessment was made in February, 1924, and a claim for abatement was made, considered, and finally rejected on July 30, 1925. 2. STATUTE OF LIMITATIONS. - Where tentative return, Form 1031-T, was filed on March 13, 1919, and the return, Form 1120, as required by law, was filed on June 16, 1919, held, that the 5-year period of…
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1. JURISDICTION. - Under the provisions of section 283(f) of the Revenue Act of 1926, the Board has jurisdiction in a case in which a jeopardy assessment was made in February, 1924, and a claim for abatement was made, considered, and finally rejected on July 30, 1925. 2. STATUTE OF LIMITATIONS. - Where tentative return, Form 1031-T, was filed on March 13, 1919, and the return, Form 1120, as required by law, was filed on June 16, 1919, held, that the 5-year period of limitation provided by section 250(d) of the Revenue Act of 1921, began to run at midnight, June 16, 1919, under authority of…
1Opinion of the Court
RELIANCE MANUFACTURING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Reliance Mfg. Co. v. Commissioner
Docket No. 6021.
United States Board of Tax Appeals
7 B.T.A. 583; 1927 BTA LEXIS 3155;
June 28, 1927, Promulgated
1. JURISDICTION. - Under the provisions of section 283(f) of the Revenue Act of 1926, the Board has jurisdiction in a case in which a jeopardy assessment was made in February, 1924, and a claim for abatement was made, considered, and finally rejected on July 30, 1925.
2. STATUTE OF LIMITATIONS. - Where tentative return, Form 1031-T, was filed on March 13, 1919, and…
2Cases cited2 opinions
- Dallas Brass & Copper Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Reliance Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1927