Warner Sugar Refining Co. v. Commissioner
United States Board of Tax Appeals
Upon the evidence held, that the assessment by the Commissioner on March 31, 1924, of a deficiency in respect of the tax for the calendar year 1917 was not barred by the statute of limitations.
1Opinion of the Court
*9OPINION.
Littleton:
This appeal does not contest the correctness of the net taxable income, nor does it allege that the Commissioner committed an error in his determination of the deficiency for the year 1917, but alleges that the Commissioner was without legal authority in March, 1924, to assess or collect the deficiency of $110,583.55. The Commissioner moves to dismiss the appeal upon th*e ground that the Board is without jurisdiction to determine the issue raised.
The Board has jurisdiction to decide the question of whether the assessment was barred by the statute of limitations. Appeal of…
2Cases cited9 opinions
- Shutte v. ThompsonSupreme Court of the United States · 1873
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3Cited by7 opinions
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- Negroni v. Secretary of the TreasurySupreme Court of Puerto Rico · 1962
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