Stetson & Ellison v. Commissioner
United States Board of Tax Appeals
Consolidated income and profits-tax returns were filed on behalf of the petitioner on June 16, 1919, and on March 15, 1920, for the years 1918 and 1919, respectively.
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Consolidated income and profits-tax returns were filed on behalf of the petitioner on June 16, 1919, and on March 15, 1920, for the years 1918 and 1919, respectively. Those returns being in substantial compliance with sections 239 and 240 of the Revenue Act of 1918, they are the returns contemplated by the statute, and, more than five years having elapsed since the filing of those returns, the Commissioner was without authority to make the assessments of June, 1925, and to assess the additional amounts proposed in the notice of deficiency of September 5, 1925.
1Opinion of the Court
STETSON & ELLISON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Stetson & Ellison v. Commissioner
Docket No. 8736.
United States Board of Tax Appeals
11 B.T.A. 397; 1928 BTA LEXIS 3814;
April 3, 1928, Promulgated
Consolidated income and profits-tax returns were filed on behalf of the petitioner on June 16, 1919, and on March 15, 1920, for the years 1918 and 1919, respectively. Those returns being in substantial compliance with sections 239 and 240 of the Revenue Act of 1918, they are the returns contemplated by the statute, and, more than five years having elapsed since the filing…
2Cases cited8 opinions
- Mabel Elevator Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- F. A. Hall Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Dallas Brass & Copper Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Stetson & Ellison v. CommissionerUnited States Board of Tax Appeals · 1928
- Matteawan Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1926
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