Legal Opinion

Paso Robles Mercantile Co. v. Commissioner

United States Board of Tax Appeals

Decided June 22, 1928No. Docket No. 11655Published

The petitioner kept its books on a fiscal year basis but filed its return on a calendar year basis. Held, that the return filed on the calendar year basis, which did not include the full taxable period, did not start the running of the statute of limitations.

1Opinion of the Court

PASO ROBLES MERCANTILE CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Paso Robles Mercantile Co. v. Commissioner

Docket No. 11655.

United States Board of Tax Appeals

12 B.T.A. 750; 1928 BTA LEXIS 3457;

June 22, 1928, Promulgated

The petitioner kept its books on a fiscal year basis but filed its return on a calendar year basis. Held, that the return filed on the calendar year basis, which did not include the full taxable period, did not start the running of the statute of limitations.

Philip G. Sheehy, Esq., for the petitioner.

A. H. Murray, Esq., for the respondent.

TRAMMELL

This…

2Cases cited6 opinions

  1. Edwards v. DouglasSupreme Court of the United States · 1925
  2. Mason v. RoutzahnSupreme Court of the United States · 1927
  3. Mabel Elevator Co. v. CommissionerUnited States Board of Tax Appeals · 1925
  4. Paso Robles Mercantile Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  5. Sunshine Cloak & Suit Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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