Legal Opinion

McFetridge v. Commissioner

United States Board of Tax Appeals

Decided December 22, 1927No. Docket No. 11210PublishedCited by 3 opinions

1. The Commissioner's action in disallowing the application of the 25 per cent reduction provided by Title XII, Revenue Act of 1924, to that portion of petitioner's income returned for 1924 which came from the proportionate 1923 earnings of her partnership, which had a fiscal year, is approved.

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1. The Commissioner's action in disallowing the application of the 25 per cent reduction provided by Title XII, Revenue Act of 1924, to that portion of petitioner's income returned for 1924 which came from the proportionate 1923 earnings of her partnership, which had a fiscal year, is approved. Charles Colip,5 B.T.A. 123, followed. 2. The status of additional notices of deficiency as to the taxable year in question, other than the notice of deficiency appealed from, discussed.

1Opinion of the Court

*762OPINION.

Love :

The respondent in his notice of deficiency, dated November 25,1925, proposed a deficiency in tax for the year 1924 in the amount of $297.52. The petitioner appealed from his action in determining that deficiency and alleged that the respondent erred in disallowing the application of 25 per cent reduction to that portion of her income returned for 1924 which came from the proportionate 1923 earnings of her partnership, which had a fiscal year. The entire deficiency resulted from such action by the respondent and consequently the issue presented is determinative thereof.

As is set…

2Cited by3 opinions

  1. McFetridge v. CommissionerUnited States Board of Tax Appeals · 1927
  2. McFetridge v. CommissionerUnited States Board of Tax Appeals · 1927
  3. McFetridge v. CommissionerUnited States Board of Tax Appeals · 1927

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