Legal Opinion

Puget Sound Nat'l Bank v. Commissioner

United States Board of Tax Appeals

Decided August 3, 1937No. Docket No. 80461Published

1. A verbal request made by a coexecutor on a collector merely for an audit of an income tax return of the estate, the substance of which the collector communicated in writing to an internal revenue agent in charge, does not meet the requirements of section 275(b) of the Revenue Act of 1928, it not being in writing or clear enough to put the Government on notice of intent to take advantage of the benefits of the shorter limitation period. 2. The executors of the taxpayer…

Read the full summary

1. A verbal request made by a coexecutor on a collector merely for an audit of an income tax return of the estate, the substance of which the collector communicated in writing to an internal revenue agent in charge, does not meet the requirements of section 275(b) of the Revenue Act of 1928, it not being in writing or clear enough to put the Government on notice of intent to take advantage of the benefits of the shorter limitation period. 2. The executors of the taxpayer were discharged within the time allowed the Commissioner for the mailing of a notice of deficiency to the taxpayer. No…

1Opinion of the Court

THE PUGET SOUND NATIONAL BANK OF TACOMA, WASHINGTON, JOHN W. DAVIS, AND MRS. MILDRED FULLER WALLACE, AS RESIDUARY LEGATEES UNDER WILL OF H. C. WALLACE, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Puget Sound Nat'l Bank v. Commissioner

Docket No. 80461.

United States Board of Tax Appeals

36 B.T.A. 386; 1937 BTA LEXIS 719;

August 3, 1937, Promulgated

1. A verbal request made by a coexecutor on a collector merely for an audit of an income tax return of the estate, the substance of which the collector communicated in writing to an internal revenue agent in charge, does not…

2Cases cited10 opinions

  1. Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
  2. Lucas v. Pilliod Lumber Co.Supreme Court of the United States · 1930
  3. Hulburd v. CommissionerSupreme Court of the United States · 1935
  4. American Equitable Assurance Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  5. Esperson v. CommissionerUnited States Board of Tax Appeals · 1928

5 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API