John Wanamaker Philadelphia v. Commissioner
United States Board of Tax Appeals
The taxpayer filed a return for its fiscal year ended January 31, 1921, on June 10, 1921. After the enactment of the Revenue Act of 1921, on May 11, 1922, it filed a second return for the fiscal year ended January 31, 1921, which showed a larger tax due than was shown on the earlier return. Held, that the statute of limitations started to operate from the date of the filing of the second return and not from June 10, 1921, the date of the filing of the first return.
1Opinion of the Court
JOHN WANAMAKER PHILADELPHIA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
John Wanamaker Philadelphia v. Commissioner
Docket No. 12913.
United States Board of Tax Appeals
8 B.T.A. 864; 1927 BTA LEXIS 2783;
October 20, 1927, Promulgated
The taxpayer filed a return for its fiscal year ended January 31, 1921, on June 10, 1921. After the enactment of the Revenue Act of 1921, on May 11, 1922, it filed a second return for the fiscal year ended January 31, 1921, which showed a larger tax due than was shown on the earlier return. Held, that the statute of limitations started to operate from…
2Cases cited3 opinions
- Mabel Elevator Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- National Refining Co. v. CommissionerUnited States Board of Tax Appeals · 1924
- John Wanamaker Philadelphia v. CommissionerUnited States Board of Tax Appeals · 1927