McKean v. Commissioner
United States Board of Tax Appeals
Where the petitioner and another filed a corporate return in the name of a joint-stock company, taxable as a corporation, and the Commissioner asserted a deficiency in corporate income and profits taxes against the association named in the return, the Board is without jurisdiction to redetermine such deficiency upon appeal by the petitioner as an individual.
1Opinion of the Court
OPINION.
MuRdock :
The deficiency notice, a copy of which was attached to the petition, was dated January 23, 1926, addressed to J. S. McKean & Sons, Ltd., New Kensington, Pá., and was alleged and admitted to have been mailed on the above date. A part of the notice was as follows:
Sirs:
An audit of your income tax return for the year 1920 discloses a deficiency in tax of $1,260.93, as shown in the attached statement.
The statement attached to the notice was designated by the symbols IT: CA: 2226-8-60D and contained the computation of a deficiency *796in corporate income and profits tax of J. S. McKean…
2Cases cited7 opinions
- Hecht v. MalleySupreme Court of the United States · 1924
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- Whitney v. BackusSupreme Court of Pennsylvania · 1892
- Stevens v. Phila. Ball-Club, Pennsylvania Court of Common Pleas, Philadelphia County1891
- Tindel v. ParkSupreme Court of Pennsylvania · 1893
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- McKean v. CommissionerUnited States Board of Tax Appeals · 1929