American Bond & Mortg. Co. v. Commissioner
United States Board of Tax Appeals
1. JURISDICTION. - For the calendar year 1920, the Commissioner determined an overassessment, which represented the difference between the amount of tax shown on the original return and the amount of the tax liability as determined by the Commissioner for said year. The Board has no jurisdiction to redetermine the tax liability for 1920 and for that year the appeal is dismissed.
Read the full summary
1. JURISDICTION. - For the calendar year 1920, the Commissioner determined an overassessment, which represented the difference between the amount of tax shown on the original return and the amount of the tax liability as determined by the Commissioner for said year. The Board has no jurisdiction to redetermine the tax liability for 1920 and for that year the appeal is dismissed. See Revenue Act of 1926, section 274(g); Cornelius Cotton Mills,4 B.T.A. 255. 2. CONSOLIDATED INVESTED CAPITAL. - In the absence of evidence to show that the determination of the respondent is erroneous in amount, we…
1Opinion of the Court
*268OPINION.
Tkammell :
The petition filed herein purports to constitute an appeal from the determination by the respondent of the petitioner’s tax liability for the calendar years 1920 and 1921, and states that the taxes in controversy are income and profits taxes for said years. It appears from the deficiency letter, as well as from the allegations of the petition, that the respondent determined an 'overassessment in the amount of $42,615.85 for the year 1920, and a deficiency in the amount of $62,452.12 for the year 1921, said overassessment representing the difference between the tax shown on…
2Cited by4 opinions
- Albert Lea Packing Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- American Bond & Mortg. Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Columbus Brick & Tile Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Golden Cycle Corp. v. CommissionerUnited States Board of Tax Appeals · 1929