Legal Opinion

Myles Salt Co. v. Commissioner

United States Board of Tax Appeals

Decided January 13, 1930No. Docket No. 21200Published

Petitioner filed a return for its fiscal year ended February 28, 1921, on May 16, 1921, which was not false or fraudulent with intent to evade tax. By reason of the change in the Revenue Act of 1921, its tax liability for the fiscal year ended February 28, 1921, was increased and under the law and regulations it was required to file a return under the provisions of that act. This it failed to do.

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Petitioner filed a return for its fiscal year ended February 28, 1921, on May 16, 1921, which was not false or fraudulent with intent to evade tax. By reason of the change in the Revenue Act of 1921, its tax liability for the fiscal year ended February 28, 1921, was increased and under the law and regulations it was required to file a return under the provisions of that act. This it failed to do. A deficiency notice for the fiscal year ended February 28, 1921, was mailed to the petitioner on September 17, 1926. Held that the assessment and collection of the deficiency is not barred by the…

1Opinion of the Court

MYLES SALT CO., LTD., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Myles Salt Co. v. Commissioner

Docket No. 21200.

United States Board of Tax Appeals

18 B.T.A. 742; 1930 BTA LEXIS 2592;

January 13, 1930, Promulgated

Petitioner filed a return for its fiscal year ended February 28, 1921, on May 16, 1921, which was not false or fraudulent with intent to evade tax. By reason of the change in the Revenue Act of 1921, its tax liability for the fiscal year ended February 28, 1921, was increased and under the law and regulations it was required to file a return under the provisions of that…

2Cases cited15 opinions

  1. United States v. Nashville, Chattanooga & St. Louis Railway Co.Supreme Court of the United States · 1886
  2. United States v. BeebeSupreme Court of the United States · 1888
  3. United States v. InsleySupreme Court of the United States · 1889
  4. Clement Gunn v. The United States of AmericaSupreme Court of the United States · 1926
  5. Simmons v. OgleSupreme Court of the United States · 1882

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