Brown-Wheeler Co. v. Commissioner
United States Board of Tax Appeals
1. Held, the Commissioner's grounds for making a jeopardy assessment under section 279 of the Act of 1926 are not subject to review. 2. Held, further, that such assessment when timely made is not invalidated by a failure to mail the notice required under subdivision (b) of the section before the expiration of the statutory period for assessment, provided such notice is mailed within the 60 days provided.
1Opinion of the Court
BROWN-WHEELER CO., INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Brown-Wheeler Co. v. Commissioner
Docket No. 38699.
United States Board of Tax Appeals
21 B.T.A. 755; 1930 BTA LEXIS 1794;
December 17, 1930, Promulgated
1. Held, the Commissioner's grounds for making a jeopardy assessment under section 279 of the Act of 1926 are not subject to review.
2. Held, further, that such assessment when timely made is not invalidated by a failure to mail the notice required under subdivision (b) of the section before the expiration of the statutory period for assessment, provided such…
2Cases cited1 opinion
- Brown-Wheeler Co. v. CommissionerUnited States Board of Tax Appeals · 1930