Legal Opinion
Rose v. Commissioner
United States Tax Court
Decided July 27, 1955No. Docket Nos. 43652, 43653, 43654Published
1Opinion of the Court
OPINION.
Raum, Judge:
1. De-ficiencies for 19J¡3; Statute of Limitations.
Petitioners urge that the assessment of the deficiencies determined for the year 1943 is barred by limitations because the statutory notices were mailed more than 3 years after the expiration of the 3-year period provided in section 275 (a) of the Internal Revenue Code of 1939.3 While conceding that the notices were mailed within the 5-year period provided in section 275 (c), as extended by waivers, they urge that that section has no application because (a) there was no “omission” from gross income, and (b), in the…
2Cases cited20 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- Switzer v. CommissionerUnited States Tax Court · 1953
- Saulsbury v. United StatesCourt of Appeals for the Fifth Circuit · 1952
- Uptegrove Lumber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
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