White v. Commissioner
United States Tax Court
Held, that a portion of the deficiency determined by the respondent, undisputed by the parties and due to standard issue adjustments, is not barred by the statute of limitations. Held, further, petitioner has failed to establish any right to relief under either section 721 or 722 (b) (4).
1Opinion of the Court
OPINION.
Mulroney, Judge:
A portion of the deficiency determined by the respondent for the period April 7 to December 31, 1942, was due to “standard issue” adjustments. No error was assigned by White in the petition to this Court as to these adjustments and he contends that this portion of the deficiency is now barred by the statute of limitations. His argument on brief is as follows:
In the case at bar, the time for the assessment of taxes against American [White’s transferor] had been extended by written consent of the parties to June 30, 1951. The respondent’s deficiency notice — the 90-day…
2Cases cited6 opinions
- Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
- Soabar Co. v. CommissionerUnited States Tax Court · 1946
- Green Spring Dairy, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Green Spring Dairy, Inc. v. CommissionerUnited States Tax Court · 1952
- Powell-Hackney Grocery Co. v. CommissionerUnited States Tax Court · 1952
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- White v. CommissionerUnited States Tax Court · 1957