Canal Bank & Trust Co. v. Commissioner

Board of Tax Appeals

Canal Bank & Trust Co. v. Commissioner

15 B.T.A. 424, 1929 BTA LEXIS 2864

CourtUnited States Board of Tax Appeals

DecidedFebruary 14, 1929

DocketDocket No. 20159.

StatusPublished

Cited by1 cases

This text of 15 B.T.A. 424 (Canal Bank & Trust Co. v. Commissioner) 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.

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Canal Bank & Trust Co. v. Commissioner, 15 B.T.A. 424, 1929 BTA LEXIS 2864 (bta 1929).

Pincite

Opinion

[425]*425OPINION.

Siefkin :

At the hearing of. this proceeding the petitioner was not represented. The only facts we have for consideration are those set forth in the petition and admitted by the respondent.

The proper return for the year 1917 was filed sometime in 1918. In the absence of waivers, assessment of taxes for 1917 would have been barred sometime during the year 1923 by the Revenue Act of 1921.

On December 13, 1922, the petitioner filed a waiver. There is no evidence to show whether this was a limited or unlimited waiver.

From the evidence before us we can not determine that the assessment of the additional tax for the year 1917 is barred.

Judgment toill he entered for the respondent.

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