Bolich v. Rubel

Rubel, the plaintiff, was the president of several corporations who filed income tax returns for the years 1926-1920, inclusive. The Commissioner found a deficiency as to all these years and sent to the companies “6(Lday letters,” to review which they filed petitions with the Board of Tax Appeals. In February, 1933, while these appeals were pending, the Commissioner sent a letter to the corporations in conformity with section 1105 of the Revenue Act of 1926, directing them to submit their books for a second examination. Upon their failure to comply, the defendant, the acting internal revenue…