A. J. Bates Co. v. United States

WILLIAMS, Judge.

The single issue presented in this case is: Was the additional tax of $5,863.62 assessed against the A. J. Bates Chicago Company by the Commissioner of Internal Revenue on December 21, 1925, barred by the statute of limitations at the time the assessment was made?

The plaintiff and the A. J. Bates Chicago Company filed a consolidated tax return for the year 1918 on June 16, 1919. The 5-year period of limitation within which a tax eould legally be assessed on the return was June 16, 1924. The tax in question was assessed on December 21, 1925, more than 18 months after the 5-year…