National Tank & Export Co. v. Commissioner
United States Board of Tax Appeals
JURISDICTION. - Under section 279 of the Revenue Act of 1924, the Board is without jurisdiction to hear and determine an appeal from a jeopardy assessment prior to the rejection of a claim for abatement.
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JURISDICTION. - Under section 279 of the Revenue Act of 1924, the Board is without jurisdiction to hear and determine an appeal from a jeopardy assessment prior to the rejection of a claim for abatement. Following Appeal of Oakdale Coal Co.,1 B.T.A. 773. STATUTE OF LIMITATIONS. - A consolidated return for two or more corporations, made in accordance with sections 239 and 240(a) of the Revenue Act of 1918, is the return required by law of each of the corporations whose net income and deductions are included therein. The period of limitation provided by section 277(a)(2) of the Revenue Act of…
1Opinion of the Court
*1220OPINION.
TRUssell : Upon the record of facts admitted and proved as above set forth, the taxpayer rests its appeal.
Respecting the assessments for the years 1919 and 1920, it appears that on or about December 29,1924, the Commissioner made so-called jeopardy assessments for which the taxpayer filed claims for abatement but omitted the furnishing of a bond as required by section 279 (a) of the Revenue Act of 1924; that up to the date of the hearing of this appeal such claims had not been acted upon by the Commissioner nor had the taxes assessed been collected. Under similar statements of fact…
2Cited by6 opinions
- General Mfg. Corp. v. CommissionerUnited States Tax Court · 1965
- General Mfg. Corp. v. CommissionerUnited States Tax Court · 1965
- Matteawan Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Morris County Crushed Stone Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- National Tank & Export Co. v. CommissionerUnited States Board of Tax Appeals · 1926
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