Bowman v. Commissioner
United States Tax Court
1. Upon the record it is found that respondent's determination as to the amount of petitioner's income for the years 1942 and 1943 was erroneous and it is held that there are no deficiencies in income tax and no penalties due from petitioner for those years. 2. Respondent determined a deficiency in income tax, together with fraud and negligence penalties, for 1943, from which the petitioner failed to file a timely petition with this Court, and the deficiency and penalties…
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1. Upon the record it is found that respondent's determination as to the amount of petitioner's income for the years 1942 and 1943 was erroneous and it is held that there are no deficiencies in income tax and no penalties due from petitioner for those years. 2. Respondent determined a deficiency in income tax, together with fraud and negligence penalties, for 1943, from which the petitioner failed to file a timely petition with this Court, and the deficiency and penalties were assessed. Following this, respondent determined a deficiency, together with penalties, for the year 1942 and an…
1Opinion of the Court
OPINION.
Leech, Judge:
The first question presented is whether this Court is without jurisdiction to redetermine petitioner’s tax liability for the year 1948. As set out in our findings, respondent determined a deficiency for that year from which petitioner failed to appeal to this Court within the statutory time, and such deficiency was assessed but appears to have been unpaid. Approximately one year later respondent, by statutory deficiency notice mailed to petitioner, determined deficiencies for 1942 and an additional deficiency for 1943. Petitioner has filed his timely petition here,…
2Cases cited3 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Last Chance Mining Co. v. Tyler Mining Co.Supreme Court of the United States · 1895
- Anderson v. CommissionerUnited States Tax Court · 1948
3Cited by25 opinions
- LTV Corp. v. CommissionerUnited States Tax Court · 1975
- Hannan v. CommissionerUnited States Tax Court · 1969
- McGowan v. CommissionerUnited States Tax Court · 1976
- Gladstone Foundation v. CommissionerUnited States Tax Court · 1981
- Intervest Enterprises, Inc. v. CommissionerUnited States Tax Court · 1972
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