Knight-Campbell Music Co. v. Commissioner
United States Board of Tax Appeals
1. A waiver entered into between the parties after the period of limitation had expired and subsequent to the passage of the Revenue Act of 1926 and prior to the Revenue Act of 1928, is ineffective, since section 1106 of that act extinguished both the right and the remedy.
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1. A waiver entered into between the parties after the period of limitation had expired and subsequent to the passage of the Revenue Act of 1926 and prior to the Revenue Act of 1928, is ineffective, since section 1106 of that act extinguished both the right and the remedy. Steiner Manufacturing Co.,18 B.T.A. 740; United States Refractories Corporation,23 B.T.A. 872, followed. 2. Where taxes were assessed before June 2, 1924, claims in abatement filed, collection stayed and payment of part of the amount assessed made within one year after the Revenue Act of 1928 was enacted, held, that section…
1Opinion of the Court
*1238OPINION.
Black :
As has already been stated in our preliminary statement, the petitioner has waived all contentions as to the assessment and collection of the deficiencies asserted by the Commissioner for all years involved in this proceeding except the eight-month period ending December 31, 1920. We will, therefore, take up the remaining issues raised by petitioner in their order.
The first is the right of the respondent to assess and collect the deficiency of $2,061.75 for the eight-month period ended December 31, 1920, the petitioner contending that the statute of limitations has tolled the…
2Cases cited4 opinions
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- Stange v. United StatesSupreme Court of the United States · 1931
- Burnet v. Chicago Railway Equipment Co.Supreme Court of the United States · 1931
- Mascot Oil Co. v. United StatesSupreme Court of the United States · 1931
3Cited by2 opinions
- Bateman v. CommissionerUnited States Board of Tax Appeals · 1936
- Knight-Campbell Music Co. v. CommissionerUnited States Board of Tax Appeals · 1931