# Chicago Insulated Wire & Mfg. Co. v. Commissioner > United States Board of Tax Appeals · March 7, 1928 · 10 B.T.A. 1195 URL: https://www.frixlaw.com/law-library/cases/4487616 ## Case - **Full name:** CHICAGO INSULATED WIRE & MANUFACTURING CO., v. COMMISSIONER OF INTERNAL REVENUE - **Court:** United States Board of Tax Appeals - **Decided:** March 7, 1928 - **Citations:** 10 B.T.A. 1195; 1928 BTA LEXIS 3931 - **Precedential status:** Published - **Opinion:** Opinion of the court by Littleton - **Judges:** Littleton - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4487616 ## Opinion text *1196 OPINION. Littleton: The written consent entered into between petitioner and the Commissioner expired April 1, 1924. The Commissioner made the assessment on March 25, 1924, which was within the period agreed upon. The amount assessed and now claimed by the Commissioner has never been collected. Since the five-year period within which the Commissioner might collect any amount from the taxpayer as a tax expired under the statute and the consent before the passage of the Revenue Act of 1924, collection of the proposed deficiency is now barred by the statute of limitations. Ocean Accident & Guarantee Corporation, Ltd., 6 B. T. A. 1045; Theodore H. Wickwire, Jr., et al., Executors, 10 B. T. A. 102; Bowers v. New York & Albany Lighterage Co., 273 U. S. 346 . Judgment of no deficiency will be entered. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4487616. Public record. Not legal advice.