Jacob A. Doll and Esther Doll v. Commissioner of Internal Revenue

Third Circuit

Jacob A. Doll and Esther Doll v. Commissioner of Internal Revenue

358 F.2d 713, 17 A.F.T.R.2d (RIA) 777, 1966 U.S. App. LEXIS 6517

CourtCourt of Appeals for the Third Circuit

DecidedApril 12, 1966

Docket15669_1

StatusPublished

Cited by18 cases

This text of 358 F.2d 713 (Jacob A. Doll and Esther Doll v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Jacob A. Doll and Esther Doll v. Commissioner of Internal Revenue, 358 F.2d 713, 17 A.F.T.R.2d (RIA) 777, 1966 U.S. App. LEXIS 6517 (3d Cir. 1966).

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Opinion

PER CURIAM.

This case is before the Court on a petition to review a decision of the Tax Court. The question before us is whether the Tax Court erred in its determination that an assessment of a tax deficiency for the taxable year 1954 was not barred by *714 the statute of limitations. 26 U.S.C.A. 6501(a). We are of the opinion that the case is governed by Lucas v. Pilliod Lumber Co., 281 U.S. 245, 50 S.Ct 297, 74 L.Ed. 829 (1930). It was therein held that the statute of limitations did not bar the assessment of a tax deficiency where, as in the instant case, the return failed to meet the requirements of the statute. The return filed by the petitioners in the case before us was not signed by either of them.

The judgment of the Tax Court will be affirmed on its opinion.

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PER CURIAM.

This case is before the Court on a petition to review a decision of the Tax Court. The question before us is whether the Tax Court erred in its determination that an assessment of a tax deficiency for the taxable year 1954 was not barred by *714 the statute of limitations. 26 U.S.C.A. 6501(a). We are of the opinion that the case is governed by Lucas v. Pilliod Lumber Co., 281 U.S. 245, 50 S.Ct 297, 74 L.Ed. 829 (1930). It was therein held that the statute of limitations did not bar the assessment of a tax deficiency where, as in the instant case, the return failed to meet the requirements of the statute. The return filed by the petitioners in the case before us was not signed by either of them.

The judgment of the Tax Court will be affirmed on its opinion.

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Bluebook (online)

358 F.2d 713, 17 A.F.T.R.2d (RIA) 777, 1966 U.S. App. LEXIS 6517, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jacob-a-doll-and-esther-doll-v-commissioner-of-internal-revenue-ca3-1966.

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