United States Holding Co. v. Commissioner
United States Tax Court
1. Respondent, after examining Pasadena's books and records for the years 1954-56, proposed certain adjustments. These adjustments were subsequently settled under administrative procedures. Thereafter, without giving proper written notice pursuant to section 7605(b), I.R.C. 1954, respondent requested permission to reexamine Pasadena's books for the same years.
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1. Respondent, after examining Pasadena's books and records for the years 1954-56, proposed certain adjustments. These adjustments were subsequently settled under administrative procedures. Thereafter, without giving proper written notice pursuant to section 7605(b), I.R.C. 1954, respondent requested permission to reexamine Pasadena's books for the same years. Such request was denied, whereupon respondent, without the aid of Pasadena's books, proposed additional adjustments for the years 1954 and 1956 which became the basis of the notice of deficiency in this case. Held, since respondent did…
1Opinion of the Court
United States Holding Co., Petitioner, v. Commissioner of Internal Revenue, Respondent
United States Holding Co. v. Commissioner
Docket No. 92152
United States Tax Court
44 T.C. 323; 1965 U.S. Tax Ct. LEXIS 76;
June 9, 1965, Filed
Decision will be entered under Rule 50.
1. Respondent, after examining Pasadena's books and records for the years 1954-56, proposed certain adjustments. These adjustments were subsequently settled under administrative procedures. Thereafter, without giving proper written notice pursuant to section 7605(b), I.R.C. 1954, respondent requested permission to reexamine…
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- Charles Oran Mensik and Mary Mensik v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Mensik v. CommissionerUnited States Tax Court · 1962
- William O'Dwyer and Sloan O'Dwyer v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959
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