Legal Opinion
Borg-Warner Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided September 29, 1981No. 80-1818PublishedCited by 26 opinions
1Opinion of the Court
WILL, Senior District Judge.
This is an appeal from the United States Tax Court’s decision in favor of the Commissioner of Internal Revenue (Commission*325er) in the amount of $4,316,132.06. The sole issue on this appeal is whether the assessed deficiency in the taxpayer’s income tax for the year 1968 was barred by the statute of limitations under 26 U.S.C. § 6501.1 For the reasons stated herein, we hold that the asserted deficiency for the year in question is barred by the statute of limitations. We therefore reverse the Tax Court’s judgment.
I. BACKGROUND
On June 3, 1969, the taxpayer filed its…
2Cases cited6 opinions
- United States v. Edward J. AhrensCourt of Appeals for the Eighth Circuit · 1976
- Jack M. Lesser v. United StatesCourt of Appeals for the Second Circuit · 1966
- McManus v. CommissionerCourt of Appeals for the Ninth Circuit · 1978
- Johnson v. CommissionerUnited States Tax Court · 1977
- Collins v. WoodworthCourt of Appeals for the Sixth Circuit · 1940
1 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Donald Feldman and Patricia Feldman, A/K/A Patsy Jane Feldman v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1994
- In Re PremoUnited States Bankruptcy Court, E.D. Michigan · 1990
- Grunwald v. CommissionerUnited States Tax Court · 1986
- Brewer v. United StatesDistrict Court, S.D. New York · 1991
- Estate of Camara v. CommissionerUnited States Tax Court · 1988
21 more not listed; retrieve them via the Exa API.