CALIFORNIA THOROUGHBRED BREEDERS ASSOCIATION v. COMMISSIONER

Docket No. 5415-64.

47 T.C. 335 (1966)

CALIFORNIA THOROUGHBRED BREEDERS ASSOCIATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 29, 1966.


Attorney(s) appearing for the Case

Adam Y. Bennion, for the petitioner.

Roger Rhodes, for the respondent.


TANNENWALD, Judge:

Respondent determined deficiencies of $13,598.20 and $1,591.17 in petitioner's Federal income tax for the taxable years 1959 and 1960, respectively. The determination involves the following issues:

(1) Whether the filing of an information return (Form 990) commenced the running of the period of limitations against assessment of the tax on unrelated business income imposed by section 511;1 and

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