# Brown v. Commissioner

> United States Board of Tax Appeals · April 19, 1927 · 6 B.T.A. 895

URL: https://www.frixlaw.com/law-library/cases/6804401

## Case

- **Full name:** George A. Brown v. Commissioner of Internal Revenue, Respondent Edward T. Brown v. Commissioner of Internal Revenue, Respondent Jonathan Brown, Jr. v. Commissioner of Internal Revenue
- **Court:** United States Board of Tax Appeals
- **Decided:** April 19, 1927
- **Citations:** 6 B.T.A. 895
- **Precedential status:** Published
- **Opinion:** Opinion of the court by Milliken
- **Judges:** Milliken
- **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/6804401

## Opinion text

*896 OPINION.
Milliken :
Section 277(a) (2) of the Revenue Act of 1924 provides that the amount of income or profits taxes imposed by “ the Revenue Act of 1916, the Revenue Act of 1917, * * * and by any such Act as amended, shall be assessed within five years after the return was filed.” The deficiency letter from which the appeal for the year 1916 was taken, was mailed to the petitioner more than five years after the return was filed on March 27,1917, and the limitation of time within which taxes must be assessed for the year 1916 had expired.
The deficiencies in tax, if any, for the years 1920 and 1921, in the three appeals, should be recomputed in accordance with the stipulations of the parties, as concerns the net income from the copartnership for those years.
Judgment will he entered on 15 days’ notice, under Bule 50.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/6804401. Public record. Not legal advice.