# Whitehouse Leather Prods. Co. v. Commissioner

> United States Board of Tax Appeals · June 19, 1928 · 12 B.T.A. 714

URL: https://www.frixlaw.com/law-library/cases/4488419

## Case

- **Full name:** WHITEHOUSE LEATHER PRODUCTS CO., INC., <emphasis typestyle="it">v.</emphasis> COMMISSIONER OF INTERNAL REVENUE
- **Court:** United States Board of Tax Appeals
- **Decided:** June 19, 1928
- **Citations:** 12 B.T.A. 714; 1928 BTA LEXIS 3479
- **Precedential status:** Published
- **Opinion:** Opinion of the court by Arundell
- **Judges:** Arundell
- **Cited by:** 1 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/4488419

## Opinion text

ARUNdell :
This proceeding involves a deficiency in income tax, in an amount not stated, for the fiscal year ended January 31, 1921. At the hearing counsel for the petitioner filed an amended petition alleging that the deficiency determined was barred by the statute of limitations, and abandoned the one allegation of error previously made.
The parties stipulated that the petitioner, while doing business under the name of Buchan-Murphy Manufacturing Company, Inc., filed a return of its income and profits taxes for the fiscal year ended January 31, 1921, on April 16, 1921; that that return was filed under *715 and pursuant to the Revenue Act of 1918; that a proper audit of that return under the provisions of the Revenue Act of 1921 would not result in a greater tax than by applying the provisions of the Revenue Act of 1918; and that the notice of deficiency was mailed to petitioner on November 9, 1925.
Under the decisions of the Board in Fred T. Ley & Co., 9 B. T. A. 749, and M. Brown & Co., 9 B. T. A. 753, assessment and collection of the deficiency determined is barred by the statute of limitations.
Judgment of no deficiency will loe entered.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4488419. Public record. Not legal advice.
