Excise taxes on the sale of batteries were illegally collected from taxpayer from April, 1919 to April, 1926. In 1926 taxpayer filed a claim for refund for taxes paid between 1922 and 1926. Refund for the payments made earlier was barred by the statute of limitations. In 1935 the refund was received, and it was taxed as income by the commissioner. In a suit by the taxpayer to recover payment of the assessment, the lower court permitted recoupment, against the income tax deficiency, of the amount of excise taxes illegally collected between 1919 and 1922. Held, reversed. The recoupment doctrine as applied to tax law must be limited to a single transaction or taxable event which has been subjected to two taxes on inconsistent legal theories. R...
Defendant was indicted for wilfully attempting to evade and defeat payment of part of his income tax...
In a prior action one of the defendants obtained a judgment against the plaintiff. The present actio...
A tax deficiency of $28,908.60 including interest was levied by the Commissioner of Internal Revenue...
Excise taxes on the sale of batteries were illegally collected from taxpayer from April, 1919 to Apr...
The commissioner determined that a deficiency existed in the taxpayer\u27s income tax for 1938. This...
Taxpayer treated the proceeds of a judgment recovered in 1954 as capital gain. Although the Commissi...
Petitioner\u27s deceased sold stock under an installment contract and made a large profit thereon. T...
In 1933, the Ohio legislature passed an act exempting from taxation certain property of interurban r...
Plaintiff, in 1935, purported to set up a trust of $300,000 for the benefit of her infant daughter; ...
During the years 1946 to 1950 a local tax upon respondent\u27s real property was assessed at one hun...
The respondent oil company in computing its net income for the years 1929-1930 for the purpose of ap...
The plaintiff taxpayer, as the general manager of a manufacturing corporation, received a bonus of a...
In 1943 the Commissioner of Internal Revenue assessed deficiencies against respondent taxpayer in it...
Since 1953, Congress has enacted at least forty-eight retroactive amendments to the revenue laws, th...
The proposition that a seller who has collected from his vendees but has not paid to the government ...
Defendant was indicted for wilfully attempting to evade and defeat payment of part of his income tax...
In a prior action one of the defendants obtained a judgment against the plaintiff. The present actio...
A tax deficiency of $28,908.60 including interest was levied by the Commissioner of Internal Revenue...
Excise taxes on the sale of batteries were illegally collected from taxpayer from April, 1919 to Apr...
The commissioner determined that a deficiency existed in the taxpayer\u27s income tax for 1938. This...
Taxpayer treated the proceeds of a judgment recovered in 1954 as capital gain. Although the Commissi...
Petitioner\u27s deceased sold stock under an installment contract and made a large profit thereon. T...
In 1933, the Ohio legislature passed an act exempting from taxation certain property of interurban r...
Plaintiff, in 1935, purported to set up a trust of $300,000 for the benefit of her infant daughter; ...
During the years 1946 to 1950 a local tax upon respondent\u27s real property was assessed at one hun...
The respondent oil company in computing its net income for the years 1929-1930 for the purpose of ap...
The plaintiff taxpayer, as the general manager of a manufacturing corporation, received a bonus of a...
In 1943 the Commissioner of Internal Revenue assessed deficiencies against respondent taxpayer in it...
Since 1953, Congress has enacted at least forty-eight retroactive amendments to the revenue laws, th...
The proposition that a seller who has collected from his vendees but has not paid to the government ...
Defendant was indicted for wilfully attempting to evade and defeat payment of part of his income tax...
In a prior action one of the defendants obtained a judgment against the plaintiff. The present actio...
A tax deficiency of $28,908.60 including interest was levied by the Commissioner of Internal Revenue...