MCFEELY

v.

COMMISSIONER OF INTERNAL REVENUE; UNITED STATES V. FIRST NATIONAL BANK OF BOSTON ET AL.; HELVERING, COMMISSIONER OF INTERNAL REVENUE, V. LEE; RAND V. HELVERING, COMMISSIONER OF INTERNAL REVENUE; AND DIBBLEE V. COMMISSIONER OF INTERNAL REVENUE

Citator

Cited By

• Simon J. Murphy Co. & Soc. Research Found., Inc. v. Commissioner OF Internal Revenue, 231 F.2d 639 (6th Cir. 1956)
  …income of the property and business of a controlled taxpayer. Section 45 had its origin in that legislation. Asiatic Petroleum Co. v. Commissioner, 2 Cir., 79 F. 2d 234, certiorari denied, 296 U.S. 645, 56 S.Ct. 248, 80 L.Ed. 459, rehearing denied, 296 U.S. 664, 56 S.Ct. 369, 80 L.Ed. 474; Welworth Realty Co., 40 B.T.A. 97; Mer [*644] tens, Law of Federal Income Taxation, Val. 8, Secs. 46.68-46.69. Litigation under the statute shows that the Section has been applied to circumstances involving an improperm…
• Brown v. The United States, 391 F.2d 653 (Ct. Cl. 1968)
  …ence the limitations period in this situation. Where language is so plain, neither construction nor resort to extrinsic evidence is needed. Helvering v. City Bank Farmers Trust Co., 296 U.S. 85, 89, 56 S.Ct. 70, 80 L.Ed. 62 (1935), rehearing denied, 296 U.S. 664, 56 S.Ct. 303, 80 L.Ed. 473. The plaintiffs admit that they were required by section 6072 (a) to file their 1955 income tax return by April 15, 1956. As that was the “date prescribed,” computation of the limitation period must commence with April 16…