SIDLES v. COMMISSIONER

Docket No. 34428.

19 T.C. 1114 (1953)

HARRY B. SIDLES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 24, 1953.


Attorney(s) appearing for the Case

J. Lee Rankin, Esq., for the petitioner.

David Karsted, Esq., for the respondent.


The Commissioner has determined a deficiency in petitioner's income tax for the year 1947 of $5,366.26. The issues for decision are:

(1) Does the statute of limitations on assessment and collection begin to run on March 15 or on a prior date where the taxpayer, reporting his income on a calendar year basis, files his final income tax return prior to March 15 of the following year under the provisions of section 58 (d) (3...

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