Legal Opinion

Keystone Coal & Mining Co. v. Commissioner

United States Board of Tax Appeals

Decided January 27, 1928No. Docket No. 10168PublishedCited by 1 opinion

The deficiency claimed herein by the Commissioner is barred by the statute of limitations. M. Brown & Co. v. Commissioner,9 B.T.A. 753, followed.

1Opinion of the Court

*296OPINION.

Green :

The petitioner contends that it is within the four-year period of limitation as provided in section 250(d) of the Revenue Act of 1921 and that this section is applicable to its return filed on September 14,1921, for the fiscal year ended on June 30, 1921. The deficiency letter was mailed on November 9, 1925, more than four yéars after the filing of the return.

The petitioner made and filed an income and profits-tax return on September 14, 1921, for the fiscal year ended June 30, 1921, and there was no claim that it was false or fraudulent with intent to evade the tax. The…

2Cases cited1 opinion

  1. Heiner v. Colonial Trust Co.Supreme Court of the United States · 1927

3Cited by1 opinion

  1. Keystone Coal & Mining Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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