Constitution Pub. Co. v. Commissioner
United States Board of Tax Appeals
A consent in writing signed by the taxpayer and the Commissioner "for the year 1922, seven months ended July 31," is effectual for extending the time for assessment for the calendar year 1922.
1Opinion of the Court
*427OPINION.
TeamMell :
The petitioner contends that the consent in writing which extends the time for making assessment of the amount of income or profits taxes due under any return “for the year 1922, seven months ended July 31,” is not sufficient to extend the time for assessing the tax for the calendar year 1922, which is the period involved in this proceeding.
The expression “for the year 1922” and the expression “seven months ended July 31” are conflicting. The “year 1922” without any qualification, can be taken as meaning the calendar year. If either expression were used alone the meaning…
2Cases cited5 opinions
- Canal Co. v. HillSupreme Court of the United States · 1872
- Pressed Steel Car Co. v. Eastern Ry. Co.Court of Appeals for the Eighth Circuit · 1903
- Tiernan v. JacksonSupreme Court of the United States · 1831
- Way v. GreerMassachusetts Supreme Judicial Court · 1907
- Cooper v. Northern Pac. Ry. Co.District Court, D. Montana · 1914
3Cited by22 opinions
- Woods v. CommissionerUnited States Tax Court · 1989
- Schulman v. CommissionerUnited States Tax Court · 1989
- Schenk v. CommissionerUnited States Tax Court · 1976
- Kelley v. CommissionerUnited States Tax Court · 1990
- Fisher v. CommissionerUnited States Tax Court · 1994
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