Sanderling, Inc. v. Commissioner
United States Tax Court
Respondent issued a notice of deficiency to petitioner covering petitioner's taxable year ended Feb. 28, 1969. Respondent subsequently conceded that petitioner was liquidated and dissolved as a corporation on Jan. 22, 1969, and that its taxable year ended on that date.
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Respondent issued a notice of deficiency to petitioner covering petitioner's taxable year ended Feb. 28, 1969. Respondent subsequently conceded that petitioner was liquidated and dissolved as a corporation on Jan. 22, 1969, and that its taxable year ended on that date. Approximately 3 years after petitioner was dissolved, petitioner's treasurer (who was also a trustee in dissolution for the benefit of petitioner's stockholders and creditors) signed a consent as such trustee to extend the statute of limitations (Form 872). A later consent was signed by a certified public accountant acting…
1Opinion of the Court
* Sanderling, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Sanderling, Inc. v. Commissioner
Docket No. 7167-73
United States Tax Court
66 T.C. 743; 1976 U.S. Tax Ct. LEXIS 71;
July 26, 1976, Filed
Decision will be entered under Rule 155.
Respondent issued a notice of deficiency to petitioner covering petitioner's taxable year ended Feb. 28, 1969. Respondent subsequently conceded that petitioner was liquidated and dissolved as a corporation on Jan. 22, 1969, and that its taxable year ended on that date. Approximately 3 years after petitioner was dissolved, petitioner's treasurer…
2Cases cited28 opinions
- Squire v. CapoemanSupreme Court of the United States · 1956
- Logan Lumber Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Tauber v. CommissionerUnited States Tax Court · 1955
- Shomaker v. CommissionerUnited States Tax Court · 1962
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