Union Plate & Wire Co. v. Commissioner
United States Board of Tax Appeals
The corporate existence of the Union Plate & Wire Co. having been wholly terminated more than three years prior to the execution of consents extending the time for the assessment of a deficiency for the fiscal year ended March 31, 1922, and to the filing of the petition herein, held that the petition must be dismissed for lack of jurisdiction.
1Opinion of the Court
*1232OPINION.
Smith:
In the original petition filed the petitioner alleged as errors:(a) The so-called waivers obtained and on file with the Commissioner are null, void, and of no effect by reason of their having been obtained by threat, coercion, and under duress and are not a written consent between the taxpayer and the Commissioner as required by the Revenue Act.(b) The Commissioner is barred by the statute of limitations in the Revenue Act of 1926 from assessing or collecting any further tax for the year in question.(c) The Commissioner is in error in disallowing the deduction of Massachusetts…
2Cases cited7 opinions
- Kohl v. United StatesSupreme Court of the United States · 1876
- National Bank v. ColbySupreme Court of the United States · 1875
- Worcester Color Co. v. Henry Wood's Sons Co.Massachusetts Supreme Judicial Court · 1911
- Thornton v. Marginal Freight Railway Co.Massachusetts Supreme Judicial Court · 1877
- Boston Tow Boat Co. v. Medford National BankMassachusetts Supreme Judicial Court · 1917
2 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Goodman v. CommissionerUnited States Tax Court · 1946
- Union Plate & Wire Co. v. CommissionerUnited States Board of Tax Appeals · 1929