Whitehouse Leather Prods. Co. v. Commissioner

Board of Tax Appeals

Whitehouse Leather Prods. Co. v. Commissioner

12 B.T.A. 714, 1928 BTA LEXIS 3479

CourtUnited States Board of Tax Appeals

DecidedJune 19, 1928

DocketDocket No. 10673.

StatusPublished

Cited by2 cases

This text of 12 B.T.A. 714 (Whitehouse Leather Prods. 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.

Bluebook

Whitehouse Leather Prods. Co. v. Commissioner, 12 B.T.A. 714, 1928 BTA LEXIS 3479 (bta 1928).

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Opinion

ARUNdell :

This proceeding involves a deficiency in income tax, in an amount not stated, for the fiscal year ended January 31, 1921. At the hearing counsel for the petitioner filed an amended petition alleging that the deficiency determined was barred by the statute of limitations, and abandoned the one allegation of error previously made.

The parties stipulated that the petitioner, while doing business under the name of Buchan-Murphy Manufacturing Company, Inc., filed a return of its income and profits taxes for the fiscal year ended January 31, 1921, on April 16, 1921; that that return was filed under [715]*715and pursuant to the Revenue Act of 1918; that a proper audit of that return under the provisions of the Revenue Act of 1921 would not result in a greater tax than by applying the provisions of the Revenue Act of 1918; and that the notice of deficiency was mailed to petitioner on November 9, 1925.

Under the decisions of the Board in Fred T. Ley & Co., 9 B. T. A. 749, and M. Brown & Co., 9 B. T. A. 753, assessment and collection of the deficiency determined is barred by the statute of limitations.

Judgment of no deficiency will loe entered.

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ARUNdell :

This proceeding involves a deficiency in income tax, in an amount not stated, for the fiscal year ended January 31, 1921. At the hearing counsel for the petitioner filed an amended petition alleging that the deficiency determined was barred by the statute of limitations, and abandoned the one allegation of error previously made.

The parties stipulated that the petitioner, while doing business under the name of Buchan-Murphy Manufacturing Company, Inc., filed a return of its income and profits taxes for the fiscal year ended January 31, 1921, on April 16, 1921; that that return was filed under [715]*715and pursuant to the Revenue Act of 1918; that a proper audit of that return under the provisions of the Revenue Act of 1921 would not result in a greater tax than by applying the provisions of the Revenue Act of 1918; and that the notice of deficiency was mailed to petitioner on November 9, 1925.

Under the decisions of the Board in Fred T. Ley & Co., 9 B. T. A. 749, and M. Brown & Co., 9 B. T. A. 753, assessment and collection of the deficiency determined is barred by the statute of limitations.

Judgment of no deficiency will loe entered.

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Bluebook (online)

12 B.T.A. 714, 1928 BTA LEXIS 3479, Counsel Stack Legal Research, https://law.counselstack.com/opinion/whitehouse-leather-prods-co-v-commissioner-bta-1928.

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