Hale v. Commissioner
United States Tax Court
Where taxpayer set forth in a dividend schedule attached to his 1936 return two amounts which he designated "Capital" and omitted them from the total amount of dividends included in taxable income, held, such amounts were omitted from gross income within the meaning of section 275 (c), 1936 Act, and the assessment of the deficiency is not barred, the notice of deficiency having been mailed within the five-year period.
1Opinion of the Court
OPINION.
Aenold, Judge:
The Commissioner determined a deficiency in income tax for the year 1936 in the amount of $1,130.13. The only question involved is whether the assessment of such deficiency is barred by section 275 of the Revenue Act of 1936.
The facts were stipulated and as stipulated are incorporated herein by reference.
The petitioner is the duly appointed and acting executrix of the estate of C. P. Hale, deceased.
The Federal income tax of decedent for the calendar year 1936 was filed with the collector of internal revenue at San Francisco, California, on March 15,1937. The notice of…
2Cited by37 opinions
- Lawrence v. CommissionerUnited States Tax Court · 1957
- Green v. CommissionerUnited States Tax Court · 1946
- Houston v. CommissionerUnited States Tax Court · 1962
- M. C. Parrish & Co. v. CommissionerUnited States Tax Court · 1944
- American Found. Co. v. CommissionerUnited States Tax Court · 1943
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