Wisconsin Farmer Co. v. Commissioner
United States Board of Tax Appeals
Immediately prior to the taxable year petitioner was notified by state taxing authorities that it owed additional state income taxes for prior taxable years. Petitioner protested assessment of such additional taxes on the ground that a statute of limitations had run with respect to some of the years and, furthermore, contended that petitioner had paid the correct taxes for all the years in question.
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Immediately prior to the taxable year petitioner was notified by state taxing authorities that it owed additional state income taxes for prior taxable years. Petitioner protested assessment of such additional taxes on the ground that a statute of limitations had run with respect to some of the years and, furthermore, contended that petitioner had paid the correct taxes for all the years in question. In the taxable year the state legislature passed a law nullifying the effect of the statute of limitations upon which petitioner relied as a bar to the action of the state taxing authorities with…
1Opinion of the Court
*119OPINION.
AetjNdell :
The question before us is whether or not petitioner is entitled to deduct from gross income of the taxable year an amount representing additional income taxes and interest thereon asserted against petitioner by the State of Wisconsin for years prior to the taxable year.
Petitioner contends that three of the years to which the additional taxes relate were barred by limitation prior to the taxable year but were reopened for assessment purposes by a statute passed by the State of Wisconsin in the taxable year. It asserts that the passage of the statute in the taxable year…
2Cases cited6 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Eingartner v. Illinois Steel Co.Wisconsin Supreme Court · 1899
- State ex rel. Globe Steel Tubes Co. v. LyonsWisconsin Supreme Court · 1924
- Banking Commission v. BuchananWisconsin Supreme Court · 1938
- Schuette v. Tax CommissionWisconsin Supreme Court · 1940
1 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- H. E. Fletcher Co. v. Comm'rUnited States Tax Court · 1951
- Wisconsin Farmer Co. v. CommissionerUnited States Board of Tax Appeals · 1942