Brown-Wheeler Co. v. Commissioner
United States Board of Tax Appeals
1. Held, the Commissioner's grounds for making a jeopardy assessment under section 279 of the Act of 1926 are not subject to review. 2. Held, further, that such assessment when timely made is not invalidated by a failure to mail the notice required under subdivision (b) of the section before the expiration of the statutory period for assessment, provided such notice is mailed within the 60 days provided.
1Opinion of the Court
OPINION.
Lansdon :
The petitioner filed its return for 1923 on March. 15, 1924, and the jeopardy assessment challenged by this appeal was made by the respondent on March 3, 1928. The original assessment was for $5,420.15; but petitioner and respondent have agreed, by stipulation, that the asserted deficiency is to be $1,941.41, and that its validity may be determined upon the sole question as to whether or not assessment and collection of such additional tax are barred by the statute of limitations.
Notice of assessment and demand for payment of the tax involved were signed by the collector of…
2Cited by7 opinions
- Human Engineering Institute v. CommissionerUnited States Tax Court · 1973
- Homan Mfg. Co., Inc. v. H. A. LongCourt of Appeals for the Seventh Circuit · 1957
- Ramos v. Secretario de HaciendaSupreme Court of Puerto Rico · 1962
- Plitt v. HofferbertDistrict Court, D. Maryland · 1955
- Brown-Wheeler Co. v. CommissionerUnited States Board of Tax Appeals · 1930
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