Legal Opinion

Gator Oil Co. v. Commissioner

United States Tax Court

Decided April 26, 1976No. Docket No. 2494-74Published

Petitioner as Sanders-Thoureen, Inc., filed its tax return for the fiscal year ended Nov. 30, 1969, on Feb. 15, 1970. Petitioner's corporate name was changed in April 1971. At a November 1972 meeting with respondent, petitioner signed a Form 977 purporting to extend the statute of limitations until Nov. 30, 1973, and a Form 2045 which makes reference to sec. 6901 which, through the provisions of sec. 6901(c), has the effect of extending the statute of limitations for 1 year…

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Petitioner as Sanders-Thoureen, Inc., filed its tax return for the fiscal year ended Nov. 30, 1969, on Feb. 15, 1970. Petitioner's corporate name was changed in April 1971. At a November 1972 meeting with respondent, petitioner signed a Form 977 purporting to extend the statute of limitations until Nov. 30, 1973, and a Form 2045 which makes reference to sec. 6901 which, through the provisions of sec. 6901(c), has the effect of extending the statute of limitations for 1 year or to Feb. 15, 1974. Respondent mailed the deficiency notice to petitioner on Jan. 18, 1974. Held: These forms were…

1Opinion of the Court

Gator Oil Company (Formerly Sanders-Thoureen, Inc.), Petitioner v. Commissioner of Internal Revenue, Respondent

Gator Oil Co. v. Commissioner

Docket No. 2494-74

United States Tax Court

66 T.C. 145; 1976 U.S. Tax Ct. LEXIS 119;

April 26, 1976, Filed

Decision will be entered for the petitioner.

Petitioner as Sanders-Thoureen, Inc., filed its tax return for the fiscal year ended Nov. 30, 1969, on Feb. 15, 1970. Petitioner's corporate name was changed in April 1971. At a November 1972 meeting with respondent, petitioner signed a Form 977 purporting to extend the statute of limitations until Nov. 30,…

2Cases cited8 opinions

  1. Commissioner v. SternSupreme Court of the United States · 1958
  2. Turnbull, Inc., Transferee (Formerly J. Gordon Turnbull, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  3. Turnbull, Inc. v. CommissionerUnited States Tax Court · 1964
  4. P. Liedtka Trucking, Inc. v. CommissionerUnited States Tax Court · 1975
  5. Bellin v. CommissionerUnited States Tax Court · 1975

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