Greene v. Commissioner
United States Board of Tax Appeals
1. A determination of deficiency in income tax subsequent to June 2, 1924, must be made in accordance with section 274(a) or (d) of the Revenue Act of 1924, and an appeal to this Board must be taken in accordance with the provisions of section 274(a) or section 279. 2. An appeal will not lie under section 279 unless a claim for abatement, accompanied by a bond, has been filed and the claim for abatement has been acted upon.
1Opinion of the Court
This appeal was submitted on the Commissioner’s motion to dismiss, upon the ground that the appeal was from an assessment made under section 274 (d) of the Revenue Act of 1924, against which the taxpayer had not filed a claim for abatement, accompanied by a bond, as required by section 279 (a) of that act.
Ivms: The taxpayer’s petition shows that no deficiency letter was ever sent to him, so far as he was able to ascertain, but that on January 10, 1925, the collector of internal revenue at Dallas sent nim a notice and demand (Form 7658) for payment of a balance of additional income tax for…
2Cited by10 opinions
- Charles Crowther and Ivy L. Crowther v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Flynn v. CommissionerUnited States Tax Court · 1963
- Cutting v. United StatesDistrict Court, E.D. New York · 1939
- Pridgen v. CommissionerUnited States Tax Court · 1969
- Cincotta v. CommissionerUnited States Tax Court · 1960
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