Legal Opinion

Southern California Loan Asso. v. Commissioner

United States Board of Tax Appeals

Decided June 25, 1926No. Docket No. 4865Published

1. When a question as to the jurisdiction of the Board is raised, that question must be determined before the Board proceeds further with the proceeding. Frost Superior Fence Co.,1 B.T.A. 1096; A. H. Stange,1 B.T.A. 810. 2. It is not the duty or province of the Board to decide questions of policy in the administration of the office of the Commissioner.

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1. When a question as to the jurisdiction of the Board is raised, that question must be determined before the Board proceeds further with the proceeding. Frost Superior Fence Co.,1 B.T.A. 1096; A. H. Stange,1 B.T.A. 810. 2. It is not the duty or province of the Board to decide questions of policy in the administration of the office of the Commissioner. Clois L. Green,2 B.T.A. 148. 3. Mailing by the Commissioner of a letter to the taxpayer by registered mail notifying the latter of a deficiency in tax, is a compliance with section 274(a) of the Revenue Act of 1924. 4. The statutory period…

1Opinion of the Court

APPEAL OF SOUTHERN CALIFORNIA LOAN ASSOCIATION.

Southern California Loan Asso. v. Commissioner

Docket No. 4865.

United States Board of Tax Appeals

4 B.T.A. 223; 1926 BTA LEXIS 2342;

June 25, 1926, Decided Submitted April 14, 1926.

1. When a question as to the jurisdiction of the Board is raised, that question must be determined before the Board proceeds further with the proceeding. Frost Superior Fence Co.,1 B.T.A. 1096; A. H. Stange,1 B.T.A. 810.

2. It is not the duty or province of the Board to decide questions of policy in the administration of the office of the Commissioner. Clois L. Green,2…

2Cases cited37 opinions

  1. Standard Oil Company of New Jersey, Appts. v. United StatesSupreme Court of the United States · 1910
  2. Church of the Holy Trinity v. United StatesSupreme Court of the United States · 1892
  3. United States v. FisherSupreme Court of the United States · 1805
  4. Knickerbocker Ice Co. v. StewartSupreme Court of the United States · 1920
  5. Grace v. American Central InsuranceSupreme Court of the United States · 1883

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