Legal Opinion

Walker v. Commissioner

United States Board of Tax Appeals

Decided February 28, 1933No. Docket Nos. 20407, 20409, 20411Published

1. Statute of limitations had tolled deficiency asserted at Docket No. 20409 when notice of deficiency was issued. 2. Earnings and profits of a corporation accrued after March 1, 1913, must be combined with operating losses sustained during the same period in order to determine the amount of earnings and profits accumulated after March 1, 1913, which may be distributed to stockholders subject to surtaxes.

1Opinion of the Court

TALBOT C. WALKER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

SUSAN D. TALBOT, A. G. HARMS, WELLS FARGO BANK & UNION TRUST COMPANY, EXECUTRIX AND EXECUTORS OF ESTATE OF WILLIAM H. TALBOT, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

WELLS FARGO BANK & UNION TRUST COMPANY, ADMINISTRATOR WITH WILL ANNEXED, ESTATE OF FREDERICK C. TALBOT, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Walker v. Commissioner

Docket Nos. 20407, 20409, 20411.

United States Board of Tax Appeals

27 B.T.A. 829; 1933 BTA LEXIS 1294;

February 28, 1933,…

2Cases cited28 opinions

  1. Southern Pacific Co. v. LoweSupreme Court of the United States · 1918
  2. Lynch v. HornbySupreme Court of the United States · 1918
  3. Russell v. United StatesSupreme Court of the United States · 1929
  4. Lynch v. TurrishSupreme Court of the United States · 1918
  5. United States v. Boston InsuranceSupreme Court of the United States · 1925

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