FOUNDATION CO. v. UNITED STATES

Nos. 42394, M-155.

15 F.Supp. 229 (1936)

FOUNDATION CO. v. UNITED STATES.

Court of Claims.

June 1, 1936.


Attorney(s) appearing for the Case

I. Herman Sher, of New York City (Satterlee & Green, of New York City, on the brief), for plaintiff.

Guy Patten, of Washington, D. C., and Frank J. Wideman, Asst. Atty. Gen., for the United States.

Before BOOTH, Chief Justice, and LITTLETON, WILLIAMS, and WHALEY, Judges.


LITTLETON, Judge.

The sole question relating to the year 1918 involved in case No. 42394 is whether a jeopardy assessment of an additional tax made by the Commissioner on December 22, 1925, under section 274 (d) of the Revenue Act of 1924, was illegal and void under the facts and circumstances disclosed by the record. While the tax liability of plaintiff for this year was under consideration by the Commissioner, plaintiff executed waivers of the statute of limitation...

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