JACOB A. DOLL AND ESTHER DOLL, PETITIONERS,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

3d Cir. | 1966-04-12
No. 15669
358 F.2d 713 United States Court of Appeals for the Third Circuit (1966) Positive Treatment
Cited by 7 cases

Opinion of the Court
PER CURIAM.

PER CURIAM.

This case is before the Court on a petition to review a decision of the Tax Court. The question before us is whether the Tax Court erred in its determination that an assessment of a tax deficiency for the taxable year 1954 was not barred by the statute of limitations. 26 U.S.C.A. 6501(a). We are of the opinion that the case is governed by Lucas v. Pilliod Lumber Co., 281 U.S. 245, 50 S.Ct 297, 74 L.Ed. 829 (1930). It was therein held that the statute of limitations did not bar the assessment of a tax deficiency where, as in the instant case, the return failed to meet the requirements of the statute. The return filed by the petitioners in the case before us was not signed by either of them.

The judgment of the Tax Court will be affirmed on its opinion.


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