AMERICAN COMMUNITY BUILDERS, INC. v. COMMISSIONER

Docket No. 84548.

36 T.C. 364 (1961)

AMERICAN COMMUNITY BUILDERS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 25, 1961.


Attorney(s) appearing for the Case

Lester Reinwald, Esq., and Charles Melvoin, Esq., for the petitioner.

David M. Robinson, Esq., for the respondent.


TIETJENS, Judge:

The Commissioner determined deficiencies in income tax of the petitioner in the amounts of $374,903.24 and $97,086.71 for the fiscal years ended June 30, 1953, and June 30, 1954, respectively. The sole issue to be decided is whether a "10-day letter" received by petitioner was a written notice of a proposed deficiency within the meaning of section 3(b), Pub. L. 86-459 (May 13, 1960), which would make 1953 petitioner's "year of change" in accounting...

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