Fred P. Pursell & Helen Pursell v. Comm'r of Internal Revenue, 315 F.2d 629 (3rd Cir. 1963). · Go Syfert
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Fred P. Pursell & Helen Pursell v. Comm'r of Internal Revenue, 315 F.2d 629 (3rd Cir. 1963). Cases Citing This Book View Copy Cite
58 citation events (2 in the last 25 years) across 7 distinct courts.
Strongest positive: Connors, Inc. v. Commissioner (tax, 1979-02-28)
Treatment trajectory · 1963 → 2026 · click a year to view as-of
1963 1994 2026
Top citers, strongest first. 6 distinct citers. How cited ↗
discussed Cited "see" Connors, Inc. v. Commissioner (2×)
Tax Ct. · 1979 · signal: see · confidence high
See discussion of the background of section 481 in Pursell v. Commissioner , 38 T.C. 263 (1962) , affd. per curiam 315 F.2d 629 (3d Cir. 1963) .
discussed Cited "see, e.g." Schumacher Trading Partners II v. United States
Fed. Cl. · 2006 · signal: see also · confidence low
Section 6501(c)(4) permits the IRS and a taxpayer to enter into an agreement to extend the limitations period for an assessment, but specifically limits such an agreement only to “particular items.” See 26 U.S.C. § 6501 (c)(4)(B) (“The Secretary shall notify the taxpayer of the taxpayer’s right to refuse to extend the period of limitations, or to limit such extension to particular issues or to a particular period of time, on each occasion when the taxpayer is requested to provide such consent.”); see also Pursell v. Comm’r, 38 T.C. 263, 278 , 1962 WL 1080 (1962), aff'd, 315 F.2d 6…
cited Cited "see, e.g." Rhone Poulenc Surfactants and Specialties, L.P. v. Commissioner
Tax Ct. · 2000 · signal: see also · confidence low
See sec. 6501(c)(4); see also Pursell v. Commissioner, 38 T.C. 263, 278 (1962), affd. 315 F.2d 629 (3d Cir. 1963).
discussed Cited "see, e.g." Wollesen v. Commissioner
Tax Ct. · 1987 · signal: see also · confidence low
See also Pursell v. Commissioner, 38 T.C. 263 , 278-279 (1962) , affd. per curiam 315 F.2d 629 (3d Cir. 1963) . (b) Validity Petitioner argues that there was no meeting of the minds between himself and respondent as to the scope of the consents to extend the statute of limitations and that the consent are therefore invalid. 2 Petitioner's argument is based on section 6501(c)(4) , which requires the parties to consent in writing on the period of extensions.
discussed Cited "see, e.g." Electric & Neon, Inc. v. Commissioner (2×)
Tax Ct. · 1971 · signal: see also · confidence low
See also Fred P. Pursell, 38 T.C. 263, 270-271 (1962), affirmed per curiam 315 F. 2d 629 (C.A. 3, 1963).
discussed Cited "see, e.g." GALE (2×)
unknown court · Rob · signal: see also · confidence low
See sec. 6501(c)(4) ; see also Pursell v. Commissioner, 38 T.C. 263 , 278 (1962) , affd. 315 F.2d 629 (3d Cir. 1963) .
Retrieving the full opinion text from the archive…
Fred P. PURSELL and Helen Pursell, Petitioners,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
14165.
Court of Appeals for the Third Circuit.
Apr 16, 1963.
315 F.2d 629
Edwin M. Kosik, Scranton, Pa. (L. E. Renard, Scranton, Pa., on the brief), for petitioners., Michael A. Mulroney, Dept, of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, David 0. Walter, Attys., Dept, of Justice, Washington, D. C., on the brief), for respondent.
Biggs, Kalodner, Forman.
Published
PER CURIAM.

We have examined the record in this case and have weighed carefully the arguments of the parties. We can perceive no error. Consequently, the decision of the Tax Court will be affirmed on the careful opinion of Judge Drennen, 38 T.C. 263.