Gator Oil Co. v. Commissioner
United States Tax Court
Petitioner as Sanders-Thoureen, Inc., filed its tax return for the fiscal year ended Nov. 30, 1969, on Feb. 15, 1970. Petitioner's corporate name was changed in April 1971. At a November 1972 meeting with respondent, petitioner signed a Form 977 purporting to extend the statute of limitations until Nov. 30, 1973, and a Form 2045 which makes reference to sec. 6901 which, through the provisions of sec. 6901(c), has the effect of extending the statute of limitations for 1 year…
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Petitioner as Sanders-Thoureen, Inc., filed its tax return for the fiscal year ended Nov. 30, 1969, on Feb. 15, 1970. Petitioner's corporate name was changed in April 1971. At a November 1972 meeting with respondent, petitioner signed a Form 977 purporting to extend the statute of limitations until Nov. 30, 1973, and a Form 2045 which makes reference to sec. 6901 which, through the provisions of sec. 6901(c), has the effect of extending the statute of limitations for 1 year or to Feb. 15, 1974. Respondent mailed the deficiency notice to petitioner on Jan. 18, 1974. Held: These forms were…
1Opinion of the Court
Sterrett, Judge:
The respondent determined a deficiency in Sanders-Thoureen, Inc.’s Federal income tax for the fiscal year ended November 30,1969, in the amount of $35,511.30. In addition to the substantive issue which gives rise to the deficiency in controversy, this case also presents two procedural issues. These issues are whether petitioner, Gator Oil Co., is the transferee of Sanders-Thoureen, Inc., within the meaning of section 6901, I.R.C. 1954, as amended1 thereby extending the statute of limitations for an additional 1-year period as provided by section 6901(c), and whether the…
2Cases cited7 opinions
- Commissioner v. SternSupreme Court of the United States · 1958
- Turnbull, Inc., Transferee (Formerly J. Gordon Turnbull, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Turnbull, Inc. v. CommissionerUnited States Tax Court · 1964
- P. Liedtka Trucking, Inc. v. CommissionerUnited States Tax Court · 1975
- Bellin v. CommissionerUnited States Tax Court · 1975
2 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Harder Services, Inc. v. CommissionerUnited States Tax Court · 1976
- Gator Oil Co. v. CommissionerUnited States Tax Court · 1976
- Harder Services, Inc. v. CommissionerUnited States Tax Court · 1976