HELVERING, COMMISSIONER OF INTERNAL REVENUE,
v.
HONNALD

U.S. | 1935-10-28
No. 454
296 U.S. 632 Supreme Court of the United States (1935) Positive Treatment
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  • …has been saying, limitation has barred the claim, it is quite clear that it is now estopped to assume an inconsistent position. [Citing authorities.]” Shamrock Oil Co. v. Commissioner of Internal Revenue, 5 Cir., 77 F. 2d 553, 555, certiorari denied 296 U.S. 632, 56 S.Ct. 155, 80 L.Ed. 449. The respondent had a right under the circumstances to direct and send the deficiency notice of December 7, 1927, as he did and was justified in treating the petitioner as the taxpayer. The notice was a valid one and the…

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