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

Court of Appeals for the Third Circuit·Decided April 12, 1966·No. 15669_1·Published·Cited by 18 cases

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.

Free access — add to your briefcase to read the full text and ask questions with AI

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.

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).

Pincite

358 F.2d 713 (Jacob A. Doll and Esther Doll v. Commissioner of Internal Revenue) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Opinion

Related