Winn v. Commissioner
United States Tax Court
Petitioner, who executed Form 872-A extending the statute of limitations on assessment of tax, was a shareholder of a subch. S corporation engaged in the inland water transportation of cargo. During 1968, in excess of 20 percent of the corporation's gross receipts consisted of "barge charter income" derived from the rental of barges on a "bareboat" basis. Petitioner made a contribution for the use of a Presbyterian missionary serving in the Korean mission field.
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Petitioner, who executed Form 872-A extending the statute of limitations on assessment of tax, was a shareholder of a subch. S corporation engaged in the inland water transportation of cargo. During 1968, in excess of 20 percent of the corporation's gross receipts consisted of "barge charter income" derived from the rental of barges on a "bareboat" basis. Petitioner made a contribution for the use of a Presbyterian missionary serving in the Korean mission field. Held, execution of the Form 872-A did not violate sec. 6501(c)(4), I.R.C. 1954, or the Fifth Amendment to the U.S. Constitution.…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in petitioners’ Federal income tax for their taxable years 1968 and 1969 in the respective amounts of $51,617.05 and $14,827.90. Concessions having been made, the following issues remain for our decision:(1) Whether Internal Revenue Service Form 872-A, executed by petitioners extending the statute of limitations on the assessment of tax for their taxable year 1968, violates section 6501(c)(4),1 I.R.C. 1954, and the Fifth Amendment to the Constitution of the United States;(2) Whether petitioners are entitled to a charitable contribution…
2Cases cited14 opinions
- Williamson v. Lee Optical of Oklahoma, Inc.Supreme Court of the United States · 1955
- Ferguson v. SkrupaSupreme Court of the United States · 1963
- The SouthwarkSupreme Court of the United States · 1903
- Western Union Telegraph Co. v. LenrootSupreme Court of the United States · 1945
- United States v. SheaSupreme Court of the United States · 1894
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3Cited by22 opinions
- Grunwald v. CommissionerUnited States Tax Court · 1986
- Estate of Camara v. CommissionerUnited States Tax Court · 1988
- Thompson v. CommissionerUnited States Tax Court · 1980
- Kovens v. CommissionerUnited States Tax Court · 1988
- Brinley v. CommissionerUnited States Tax Court · 1984
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