Haberland v. Commissioner
United States Board of Tax Appeals
1. DEDUCTION - INVOLUNTARY CONVERSION. In 1918 the Alien Property Custodian seized and sold petitioner's stock in a domestic corporation engaged in the manufacture of textiles.
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1. DEDUCTION - INVOLUNTARY CONVERSION. In 1918 the Alien Property Custodian seized and sold petitioner's stock in a domestic corporation engaged in the manufacture of textiles. The stock was sold for a sum in excess of cost to petitioner or its March 1, 1913, value and the proceeds were turned over to petitioner in October, 1921. In November, 1921, petitioner organized a corporation to engage in making sizing materials for sale to textile mills, and from time to time over a period of years made advances to the new corporation out of the funds turned over to him by the Custodian. Stock of the…
1Opinion of the Court
*1376OPINION.
ARUNdell:
Several of the questions involved in the present step in this proceeding may be disposed of without much discussion. The first is the question of the statute of limitations. We fail to see any merit in the petitioner’s contention that the statute has run against assessment and collection. His return for 1918 was *1377filed on May 4, 1922, and the deficiency notice was issued April 28, 1927, less than five years after the date of filing. Petitioner argues that he was not taxable for the year 1918 and was not required to file a return. Whether he was taxable or not, he had…
2Cases cited3 opinions
- Towne v. EisnerSupreme Court of the United States · 1918
- Dickerman v. Northern Trust Co.Supreme Court of the United States · 1900
- Bonwit Teller & Co. v. United StatesSupreme Court of the United States · 1931
3Cited by28 opinions
- Lynchburg Nat. Bank & Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Loco Realty Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
- Liant Record, Inc., William I. Alpert and Paula G. Alpert, Abraham Alpert and Sarah Alpert, Jack L. Alpert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Steuart Brothers, Inc., a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
- Klemp v. CommissionerUnited States Tax Court · 1981
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