Continental Products Co. v. Commissioner
United States Board of Tax Appeals
1. Affiliation denied. 2. Assessment and/or collection of taxes for the years 1918, 1919, and 1920 held not barred by the statute of limitations. 3. The Board is without power to adjudicate whether the circumstances upon which the Commissioner acted were such as to denote that the assessment or collection of the deficiency would be jeopardized by delay.
Read the full summary
1. Affiliation denied. 2. Assessment and/or collection of taxes for the years 1918, 1919, and 1920 held not barred by the statute of limitations. 3. The Board is without power to adjudicate whether the circumstances upon which the Commissioner acted were such as to denote that the assessment or collection of the deficiency would be jeopardized by delay. Veeder v. Commissioner, 36 Fed.(2d) 342. 4. The petitioner's objections to the validity of section 274(d) of the Revenue Act of 1921 are not sustained.
1Opinion of the Court
*819OPINION.
Lansdon:
These proceedings, which by order have been consolidated for hearing and decision, were instituted for a redetermination of deficiencies in income taxes for the calendar years 1918, 1919, and 1920 in the total amounts of $1,589,419.31, $871,498.62, and $24,222.88, respectively. The appeal in Docket No. 5057 is from the partial rejection of a claim in abatement covering an amount of $890,962.71 assessed for the year 1918, which was allowed to the extent of $23,317.66, and rejected as to the balance of $867,645.05. Docket No. 21842 also involves the year 1918, being an appeal…
2Cases cited5 opinions
- Den Ex Dem. Murray v. Hoboken Land & Improvement Co.Supreme Court of the United States · 1856
- Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
- Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
- Springer v. United StatesSupreme Court of the United States · 1881
- Bailey, Collector of Internal Revenue v. GeorgeSupreme Court of the United States · 1922
3Cited by6 opinions
- Aldridge v. CommissionerUnited States Tax Court · 1968
- Signal Gasoline Corporation v. United StatesDistrict Court, S.D. California · 1942
- Continental Products Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Continental Products Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Dubois Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1930
1 more not listed; retrieve them via the Exa API.