Deakman-Wells Co. v. Commissioner
United States Tax Court
Increased deficiency claimed in amended answer more than 5 years after return filed held not barred by 5-year statute of limitations effective when more than 25 per cent of gross income is omitted from return, timely deficiency notice having been mailed within 5 years and petition for redetermination thereof duly filed.
1Opinion of the Court
OPINION.
Opper, Judge:
Petitioner did not file its returns and compute its tax in accordance with the accounting method employed in keeping its books. These are circumstances authorizing respondent to require .that correct returns be filed. C. A. Carver, 10 T. C. 171, affd. (C. A. 6) 173 F. 2d 29. As petitioner itself describes its action: “It kept its books on an accrual basis and it stated its income figures, including the amount of its gross income, in its tax return on an accrual basis. However, the taxpayer then proceeded, doing so by plain statement thereof on the face of the return, to…
2Cases cited10 opinions
- Reis v. CommissionerUnited States Tax Court · 1942
- Sullenger v. CommissionerUnited States Tax Court · 1948
- Leuthesser v. CommissionerUnited States Tax Court · 1952
- M. C. Parrish & Co. v. CommissionerUnited States Tax Court · 1944
- Carver v. CommissionerUnited States Tax Court · 1948
5 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Scar v. CommissionerUnited States Tax Court · 1983
- Lawrence v. CommissionerUnited States Tax Court · 1957
- Colony, Inc. v. CommissionerUnited States Tax Court · 1956
- Patchen v. CommissionerUnited States Tax Court · 1956
- Josef C. Patchen and Aleyne E. Patchen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
18 more not listed; retrieve them via the Exa API.