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COLONY, INC. v. COMMISSIONER OF INTERNAL REVENUE

No. 13008.

244 F.2d 75 (1957)

The COLONY, Inc., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

April 22, 1957.

Attorney(s) appearing for the Case

Richard C. Oldham and Baldwin C. Burnam, Louisville, Ky., for petitioner.

Charles K. Rice, John Potts Barnes, Lee A. Jackson, Robert N. Anderson, Grant M. Wiprud, John M. Morawski, and Marvin W. Weinstein, Washington, D. C., for respondent.

Before McALLISTER, MILLER and STEWART, Circuit Judges.

PER CURIAM.

The sole question on this review is whether the five-year statute of limitations contained in section 275(c) of the Internal Revenue Code of 1939, 26 U.S. C.A. § 275(c) was applicable in this case, as the Tax Court held.1

The petitioner is a corporation dealing in real estate. Its income tax returns for the years in question contained understatements of gross income of...

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