Bishop v. Commissioner
United States Tax Court
Pursuant to an adjustment authorized by section 3801, Internal Revenue Code of 1939, the respondent mailed a notice of deficiency in petitioner's income tax for the year 1943 within the 1-year limitation contained in section 3801 (c). Held, the notice was valid and timely, and the assessment and collection of the tax was suspended by section 277 of the Code until the expiration of the period prescribed therein.
1Opinion of the Court
OPINION.
LeMike, Judge:
This proceeding involves a deficiency in petitioner’s income tax for the year 1943 in the amount of $1,064.81, determined pursuant to section 3801 of the Internal Revenue Code of 1939.
The issue is: Where a notice of deficiency mailed within 1 year, as provided in section 3801 (c), is contested, does section 277 of the Code become operative to suspend the assessment and collection of the deficiency for the further period prescribed therein ?
The facts are either stipulated or admitted in the pleadings and are not in dispute. They may be summarized as follows:
Petitioner was…
2Cases cited7 opinions
- Sgambati v. United StatesCourt of Appeals for the Second Circuit · 1949
- Ketcham v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1944
- Burton v. CommissionerUnited States Tax Court · 1943
- Bishop v. ReichelDistrict Court, N.D. New York · 1954
- Crampton v. D. V. Frione Co.District Court, D. Connecticut · 1932
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Bishop v. CommissionerUnited States Tax Court · 1956