Appeal of Moyer

Board of Tax Appeals

Appeal of Moyer

1 B.T.A. 75

CourtUnited States Board of Tax Appeals

DecidedNovember 19, 1924

DocketDocket No. 250

StatusPublished

Cited by2 cases

This text of 1 B.T.A. 75 (Appeal of Moyer) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Appeal of Moyer, 1 B.T.A. 75 (bta 1924).

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Opinion

OPINION.

Ivins: The taxpayer here has mistaken his remedy. Under section 228 of the Revenue Act of 1921 and Regulations interpreting it, the collector of internal revenue made a preliminary audit of certain returns. It would seem that the letter received by the taxpayer was the result of such an audit in the collector’s office. Under the provisions of the section mentioned, the taxpayer may appeal to the Commissioner from the collector’s decision. There is no provision of law for an appeal to this Board until after the Commissioner has made a determination. The petition must be dismissed.

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OPINION.

Ivins: The taxpayer here has mistaken his remedy. Under section 228 of the Revenue Act of 1921 and Regulations interpreting it, the collector of internal revenue made a preliminary audit of certain returns. It would seem that the letter received by the taxpayer was the result of such an audit in the collector’s office. Under the provisions of the section mentioned, the taxpayer may appeal to the Commissioner from the collector’s decision. There is no provision of law for an appeal to this Board until after the Commissioner has made a determination. The petition must be dismissed.

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Bluebook (online)

1 B.T.A. 75, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-moyer-bta-1924.

Opinion

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