Greylock Mills v. Commissioner
United States Board of Tax Appeals
1. An unlimited waiver executed January 22, 1923, with regard to taxes for 1917, held to expire April 1, 1924. 2. Notice of acceptance of unlimited waiver by the Commissioner not necessary to constitute valid consent if waiver is actually signed on behalf of the Commissioner. 3. The fact that an unlimited waiver covers years 1917-1920 does not operate to invalidate the waiver as to the years 1918-1920 simply because waiver for 1917 has expired. 4. Held that assessment and…
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1. An unlimited waiver executed January 22, 1923, with regard to taxes for 1917, held to expire April 1, 1924. 2. Notice of acceptance of unlimited waiver by the Commissioner not necessary to constitute valid consent if waiver is actually signed on behalf of the Commissioner. 3. The fact that an unlimited waiver covers years 1917-1920 does not operate to invalidate the waiver as to the years 1918-1920 simply because waiver for 1917 has expired. 4. Held that assessment and collection on December 18, 1925, of taxes for 1918 and 1919 were not barred by the statute of limitations; where an…
1Opinion of the Court
*1285OPINION.
Siepkin :
In this case the question is presented as to whether the statute of limitations has run against the proposed deficiencies for the year 1917, the six-month period ended June 30, 1918, and the fiscal year ended June 30, 1919, and had run against taxes which were collected on October 5,1925, the same being an assessment made-on January 3, 1920, of additional taxes asserted to be due on the *1286return for the jrear 1917, and a portion of the taxes shown to be due by the taxpayer on the return for the fiscal year ended June 30, 1919, assessed November 26, 1919. The deficiency claimed…
2Cited by17 opinions
- McManus v. CommissionerUnited States Tax Court · 1975
- Mecom v. CommissionerUnited States Tax Court · 1993
- Findlay v. CommissionerUnited States Tax Court · 1962
- Estate of Camara v. CommissionerUnited States Tax Court · 1988
- Simmons v. WestoverDistrict Court, S.D. California · 1948
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