Notes of Decisions
Page v. Lafayette Worsted Co., 66 F.2d 339 (1st Cir. 1933).
· cites it 4× “But in that case the question was as to the value of securities in 1913, and the change was made, not by the Commissioner who made the first valuation, but by a successor.”
Naumkeag Steam Cotton Co. v. United States, 2 F. Supp. 126 (Ct. Cl. 1933).
· cites it 2× “The quoted statement was made with reference to the plaintiff's contention that at the time the commissioner wrote the collector a letter to apply an overpayment for 1918 and 1919 by Daube, which overpayments had been timely allowed, against a profits tax due by a partnership…”
McIlhenny v. Comm'r of Internal Revenue, 39 F.2d 356 (3rd Cir. 1930).
“31, thus: “Under the present method of procedure a taxpayer never knows when he is through, as a tax ease may be opened at any time because of a change in ruling-by the treasury department.”
Simmons Mfg. Co. v. Routzahn, 62 F.2d 947 (6th Cir. 1933).
· cites it 2× “Congress undertook to do that by section 1106 (a) of the Revenue Act of 1926 (26 USCA § 1249, note), printed in the margin, 2 but repealed the section as of the date of its enactment by section 612 of the Revenue Act of 1928 ( 45 Stat.”
Mascot Oil Co. v. United States, 42 F.2d 309 (Ct. Cl. 1930).
· cites it 2× “Case, supra, we held that section 1106(a) of the act of 1926 (26 USCA § 1249 note) was of no benefit to the plaintiff where the taxes in question had been collected prior to the time when the revenue bill of 1926 went into effect unless it was‘shown that the taxes were overpaid.…”
Backus v. United States, 59 F.2d 242 (Ct. Cl. 1932).
“Finally it is contended on behalf of the plaintiff that this case was not finally settled by a closing agreement, as provided by section 1006, Revenue Act of 1924 (26 USCA § 1249 note), first enacted in the Revenue Act of 1921, and the.”
Trumbull Steel Co. v. United States, 1 F. Supp. 762 (Ct. Cl. 1932).
· cites it 2× “But the application of the 1924 act had not been definitely settled at the time the payments in the ease at bar were made, and, considering the fact that section 1106 of the Bevenue Act of 1926 (26 USCA § 1249 note) was then in force, the whole legal situation was at that time…”
Bankers' Reserve Life Co. v. United States, 42 F.2d 313 (Ct. Cl. 1930).
“Subsequent to the determination, assessment, and payment of the tax and interest-in question, plaintiff and the Commissioner, with the approval of the Secretary of the Treasury, on February 25, 1928, executed an agreement to the final determination and assessment of its tax for…”
Larkin v. United States, 78 F.2d 951 (8th Cir. 1935).
“” Appellants further contend that if any tax was due the United States by reason of the receipt of the stock by the taxpayers in 1920, such tax was barred by the statute of limitations on March 15, 1926, and all liability extinguished.”
Aetna Life Ins. Co. v. Eaton, 43 F.2d 711 (2d Cir. 1930).
“The closing agreement signed by the Commissioner on January 14, 1928, was made *713 under the authority of section 1106 (b) of the Revenue Aet of 1926 (26 USCA § 1249 note), which read as.’follows: “If after a determination and assessment in any ease the taxpayer has paid in…”
Pac. Coast Steel Co. v. McLaughlin, 61 F.2d 73 (9th Cir. 1932).
“Our conclusion that the waiver of December 7, 1925, is valid and appellants’ concession relative thereto disposes of any necessity of considering section 1106 (a) of the Revenue Act of 1926 (26 USCA § 1249 note) that provided that the bar of the statute of limitations against…”
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