Fred T. Ley & Co. v. Commissioner
United States Board of Tax Appeals
Petitioner made and filed an income and profits-tax return on June 15, 1921, for its fiscal year ended February 28, 1921, which was not false or fraudulent with intent to evade the tax. Petitioner was not liable for an additional tax for such taxable year after the enactment of the Revenue Act of 1921 by reason of any change in the law.
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Petitioner made and filed an income and profits-tax return on June 15, 1921, for its fiscal year ended February 28, 1921, which was not false or fraudulent with intent to evade the tax. Petitioner was not liable for an additional tax for such taxable year after the enactment of the Revenue Act of 1921 by reason of any change in the law. Held that the return filed on June 15, 1921, was a legal return for the taxable year under the law and regulations, and operated to start the running of the statute of limitation of four years. Held, further, that since the deficiency notice for the taxable…
1Opinion of the Court
FRED T. LEY & CO., INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Fred T. Ley & Co. v. Commissioner
Docket No. 18168.
United States Board of Tax Appeals
9 B.T.A. 749; 1927 BTA LEXIS 2521;
December 21, 1927, Promulgated
Petitioner made and filed an income and profits-tax return on June 15, 1921, for its fiscal year ended February 28, 1921, which was not false or fraudulent with intent to evade the tax. Petitioner was not liable for an additional tax for such taxable year after the enactment of the Revenue Act of 1921 by reason of any change in the law. Held that the return filed…
2Cases cited4 opinions
- John Wanamaker Philadelphia v. CommissionerUnited States Board of Tax Appeals · 1927
- Fred T. Ley & Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Davis Feed Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- Covert Gear Co. v. CommissionerUnited States Board of Tax Appeals · 1926