Goldring v. Commissioner
United States Tax Court
Petitioners filed original returns for the calendar year 1945 which omitted more than 25 per cent of their gross income. Fifteen months later they filed amended returns which purported to correct, in part, the original omission so as to reduce it below 25 per cent. Held, respondent did not err in asserting the deficiency under section 275 (c).
1Opinion of the Court
OPINION.
Bruce, Judge:
The sole question is whether the assessment and collection of the deficiencies asserted by respondent for the year 1945 are barred by the statute of limitations, section 275, Internal Revenue Code. There is no contest between the parties on the correctness of the deficiencies. Section 275 provides in part as follows:
SEC. 275. PERIOD OP LIMITATION UPON ASSESSMENT AND COLLECTION.
Except as provided in section 276—(a) General Rule. — The amount of income taxes imposed by this chapter shall be assessed within three years after the return was filed, and no proceeding in court…
2Cases cited18 opinions
- Haggar Co. v. Helvering, Com'r of Internal RevenueSupreme Court of the United States · 1940
- J. E. Riley Investment Co. v. CommissionerSupreme Court of the United States · 1940
- Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
- George M. Still, Inc. v. CommissionerUnited States Tax Court · 1953
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3Cited by39 opinions
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Bennett v. CommissionerUnited States Tax Court · 1958
- Magill v. CommissionerUnited States Tax Court · 1978
- Houston v. CommissionerUnited States Tax Court · 1962
- Dowell v. CommissionerUnited States Tax Court · 1977
34 more not listed; retrieve them via the Exa API.