Corn Products Ref. Co. v. Commissioner
United States Board of Tax Appeals
A consent in writing signed by a taxpayer prior to the passage of the Revenue Act of 1926, but not by the Commissioner until after the enactment of the Revenue Act of 1928, is not effective for extending the period for collection of taxes otherwise barred when the 1926 Act was passed.
1Opinion of the Court
*617OPINION.
Trammell :
This proceeding has been limited to questions involving the expiration of the periods of limitation. On this question three issues are presented: (1) with respect to the deficiency of $2,299,-428.87 for 1918, (2) with respect to the amount of $1,044,024.10 for 1918, (3) with respect to the amount of $350,587.38 for 1919.
The $1,044,024.10 was collected on October 27, 1925.
*618With respect to the deficiency for 1918 still unpaid, four waivers were signed by the taxpayer, the first dated August 14, 1924, which was filed August 15, 1924, and duly signed by the Commissioner. This…
2Cases cited22 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Rock Island, Arkansas & Louisiana Railroad v. United StatesSupreme Court of the United States · 1920
- Johnson v. Southern Pacific Co.Supreme Court of the United States · 1904
- Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
- Shaw v. Railroad Co.Supreme Court of the United States · 1880
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3Cited by11 opinions
- Frederic P. Holbrook, Trustee in Bankruptcy of the Estate of Mitchell H. Hewitt, Bunkrupt v. United StatesCourt of Appeals for the Ninth Circuit · 1960
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- Sneed v. CommissionerUnited States Board of Tax Appeals · 1934
- American Ry. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Simmons v. WestoverDistrict Court, S.D. California · 1948
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