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Bufferd Vs. Commissioner

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  • US Supreme Court
  • Nov 30, 1992

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34 entries 1 linked 33 unlinked
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  1. Germantown Trust Co. Vs. Commissioner US Supreme Court · Feb 26, 1940
  2. U.S. 523 (1992) October Term, 1992 Syllabus Bufferd V. Commissioner
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  3. s taxes and thus should not be regarded as triggering the period of assessment. Cf. Automobile Club of Mich. v. Commissioner
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  4. year assessment period had lapsed. The Tax Court found for the Commissioner, relying on its decision in Fehlhaber v. Commissioner
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  5. Kelley v. Commissioner
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  6. The Fifth and Eleventh Circuits have joined the Second Circuit in declining to follow Kelley. See Green v. Commissioner
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  7. Fehlhaber v. Commissioner
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  8. generally should not be regarded as triggering the period of assessment. Automobile Club of Mich. v. Commissioner
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  9. U. S. 180 , 188 (1957) (citing Commissioner v. Lane-
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  10. one to say the least, and we should accept it absent convincing grounds for rejecting it. As noted in Badaracco v. Commissioner
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  11. taxes otherwise due and unpaid are strictly construed in favor of the Government.''' Id., at 392 (quoting Lucia v. United
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  12. to set the starting date of the 3-year period within which that determination had to be made. See United States v. Adams
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  13. see also 952 F. 2d, at 677 (citing Fehlhaber v. Commissioner
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  14. cf. Germantown Trust Co. v. Commissioner
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  15. Mason v. United
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  16. contains evidence in support of the Commissioner's interpretation. See, e. g., Green v. Commissioner
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  17. purposes of the provisions of chapter 66, relating to limita- 531 The Ninth Circuit's rejection in Kelley v. Commissioner
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  18. would seem to support the Commissioner's view, petitioner, following the reasoning of the Ninth Circuit in Kelley v. Commissioner
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  19. Seatrain Shipbuilding Corp. v. Shell
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  20. made to a corporation's return years after it was filed. The Fifth Circuit's opinion by Judge Goldberg in Green v. Commissioner
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  21. Id., at 789.11 Commissioner. See Leonhart v. Commissioner
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  22. the Commissioner maintained that the opposite is the case, see Tr. of Oral Arg. 27-28, relying mainly on Commissioner v. Munter
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  23. Lardas v. Commissioner
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  24. Syllabus Bufferd V. Commissioner
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  25. Cf. Automobile Club of Mich. v. Commissioner
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  26. Kelley. See Green v. Commissioner
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  27. Automobile Club of Mich. v. Commissioner
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  28. Commissioner v. Lane-
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  29. Badaracco v. Commissioner
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  30. Lucia v. United
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  31. See United States v. Adams
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  32. Green v. Commissioner
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  33. Commissioner. See Leonhart v. Commissioner
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  34. Commissioner v. Munter
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