Legal Opinion

Southern Pacific Co. v. Commissioner

United States Board of Tax Appeals

Decided December 30, 1930No. Docket Nos. 7718, 18333, 18337Published

1. A person required by law to withhold the tax on interest payable to nonresident aliens on tax-free covenant bonds and expressly made liable for the tax, is not a taxpayer within section 274, Revenue Act of 1924, and is incompetent to bring a proceeding before the Board based on a notice of liability sent by the Commissioner prior to the enactment of the Revenue Act of 1926. 2. Section 283 (a), Revenue Act of 1926, which made notice of liability to the person liable for…

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1. A person required by law to withhold the tax on interest payable to nonresident aliens on tax-free covenant bonds and expressly made liable for the tax, is not a taxpayer within section 274, Revenue Act of 1924, and is incompetent to bring a proceeding before the Board based on a notice of liability sent by the Commissioner prior to the enactment of the Revenue Act of 1926. 2. Section 283 (a), Revenue Act of 1926, which made notice of liability to the person liable for the tax equally effective to establish jurisdiction as a notice of deficiency does not apply to notices given prior to its…

1Opinion of the Court

SOUTHERN PACIFIC CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

CENTRAL PACIFIC RAILWAY CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

SOUTHERN PACIFIC RAILROAD CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Southern Pacific Co. v. Commissioner

Docket Nos. 7718, 18333, 18337.

United States Board of Tax Appeals

21 B.T.A. 990; 1930 BTA LEXIS 1760;

December 30, 1930, Promulgated

1. A person required by law to withhold the tax on interest payable to nonresident aliens on tax-free covenant bonds and expressly made liable for the tax, is not a…

2Cases cited1 opinion

  1. Southern Pacific Co. v. CommissionerUnited States Board of Tax Appeals · 1930

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