Mantzel v. Commissioner
United States Tax Court
Ps and R's delegate executed a consent extending the period of the statute of limitations in this case, but such consent was not dated. Held, R failed to carry his burden of proving that such consent was executed prior to the running of the period of limitations.
1Opinion of the Court
THOMAS T. MANTZEL and PAMELA S. NICKERSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Mantzel v. Commissioner
Docket No. 4182-79.
United States Tax Court
T.C. Memo 1981-169; 1981 Tax Ct. Memo LEXIS 571; 41 T.C.M. (CCH) 1237; T.C.M. (RIA) 81169;
April 9, 1981.
Ps and R's delegate executed a consent extending the period of the statute of limitations in this case, but such consent was not dated. Held, R failed to carry his burden of proving that such consent was executed prior to the running of the period of limitations.
Fred A. Sanders and Cordell B. Moore, Jr., for the petitioners.
Mar…
2Cases cited5 opinions
- Farmers Feed Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- United States v. Juanita C. Gurley, Formerly Juanita C. HillCourt of Appeals for the Fifth Circuit · 1969
- Bonwit Teller & Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Eclipse Lawn Mower Co. v. United StatesUnited States Court of Claims · 1932
- Marquis v. United StatesDistrict Court, C.D. California · 1972
3Cited by2 opinions
- United States v. Hitachi America, Ltd.United States Court of International Trade · 1997
- J.H. Rutter Rex Mfg. Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988