Smith v. Commissioner
United States Tax Court
1. The Commissioner's statutory notices asserting transferee liability against petitioners were mailed more than four years after the filing of the alleged transferor's tax returns. A stipulation was filed at the hearing admitting that there were due from the alleged transferor deficiencies and fraud penalties arising out of the filing of those returns. Held: The stipulation constituted an admission by petitioners of the alleged transferor's deficiencies and fraud.
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1. The Commissioner's statutory notices asserting transferee liability against petitioners were mailed more than four years after the filing of the alleged transferor's tax returns. A stipulation was filed at the hearing admitting that there were due from the alleged transferor deficiencies and fraud penalties arising out of the filing of those returns. Held: The stipulation constituted an admission by petitioners of the alleged transferor's deficiencies and fraud. Consequently, assertion of transferee liability against petitioners is not barred by the 4-year period of limitations provided…
1Opinion of the Court
Jonnie Lou Smith, et al. 1 v. Commissioner.
Smith v. Commissioner
Docket Nos. 45853-56855.
United States Tax Court
T.C. Memo 1955-183; 1955 Tax Ct. Memo LEXIS 155; 14 T.C.M. (CCH) 706; T.C.M. (RIA) 55183;
June 30, 1955
1. The Commissioner's statutory notices asserting transferee liability against petitioners were mailed more than four years after the filing of the alleged transferor's tax returns. A stipulation was filed at the hearing admitting that there were due from the alleged transferor deficiencies and fraud penalties arising out of the filing of those returns. Held: The stipulation…
2Cases cited14 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Reis v. CommissionerUnited States Tax Court · 1942
- Gordon v. SpellmanSupreme Court of Georgia · 1916
- Rowen v. CommissionerUnited States Tax Court · 1952
- Beasley v. SmithSupreme Court of Georgia · 1915
9 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- McAllister v. Comm'rUnited States Tax Court · 2013