Bateman v. Commissioner
United States Board of Tax Appeals
1. Where taxpayer signed a waiver after the expiration of the statutory period of limitations and claims that the signed such waiver under a mistake due to lack of knowledge that such period had expired, held such waiver is valid in the absence of clear and satisfactory proof of such mistake and in the absence of evidence showing that his counsel, upon whose advice he signed such waiver, was ignorant of the facts or his rights, knowledge of counsel being imputable to his…
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1. Where taxpayer signed a waiver after the expiration of the statutory period of limitations and claims that the signed such waiver under a mistake due to lack of knowledge that such period had expired, held such waiver is valid in the absence of clear and satisfactory proof of such mistake and in the absence of evidence showing that his counsel, upon whose advice he signed such waiver, was ignorant of the facts or his rights, knowledge of counsel being imputable to his client. 2. Where a waiver, unlimited as to time, was signed by taxpayer and notice of deficiency was mailed about four and…
1Opinion of the Court
F. L. BATEMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Bateman v. Commissioner
Docket No. 47772.
United States Board of Tax Appeals
34 B.T.A. 351; 1936 BTA LEXIS 709;
April 17, 1936, Promulgated
1. Where taxpayer signed a waiver after the expiration of the statutory period of limitations and claims that the signed such waiver under a mistake due to lack of knowledge that such period had expired, held such waiver is valid in the absence of clear and satisfactory proof of such mistake and in the absence of evidence showing that his counsel, upon whose advice he signed such…
2Cases cited35 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Bull v. United StatesSupreme Court of the United States · 1935
- Burnet v. ClarkSupreme Court of the United States · 1932
- Buck v. KuykendallSupreme Court of the United States · 1925
- Dalton v. BowersSupreme Court of the United States · 1932
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