Harrington v. Commissioner
United States Tax Court
1. Following an initial audit, petitioners received a communication from the district director of internal revenue stating that their returns for 1959 and 1960 would be accepted as filed.
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1. Following an initial audit, petitioners received a communication from the district director of internal revenue stating that their returns for 1959 and 1960 would be accepted as filed. Held, this routine letter did not constitute a closing agreement under sec. 7121, I.R.C. 1954 2. Held, further: A reexamination of petitioners' returns and records for the years 1959 and 1960 did not violate sec. 7605 (b), I.R.C. 1954. Petitioners acquiesced in the examination, and, in any event, respondent literally satisfied the provisions of the statute permitting such a reaudit when the taxpayer was…
1Opinion of the Court
H. M. Harrington, Jr., and Marguerite Harrington, Petitioners v. Commissioner of Internal Revenue, Respondent
Harrington v. Commissioner
Docket No. 3061-64
United States Tax Court
48 T.C. 939; 1967 U.S. Tax Ct. LEXIS 32; 27 Oil & Gas Rep. 355;
September 29, 1967, Filed
Decision will be entered under Rule 50.
1. Following an initial audit, petitioners received a communication from the district director of internal revenue stating that their returns for 1959 and 1960 would be accepted as filed. Held, this routine letter did not constitute a closing agreement under sec. 7121, I.R.C. 1954
2. Held,…
2Cases cited17 opinions
- Palmer v. BenderSupreme Court of the United States · 1932
- Anderson v. HelveringSupreme Court of the United States · 1940
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Helvering v. Bankline Oil Co.Supreme Court of the United States · 1938
- Parsons v. SmithSupreme Court of the United States · 1959
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