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COLONY, INC. v. COMMISSIONER

No. 306.

357 U.S. 28 (1958)

78 S.Ct. 1033

2 L.Ed.2d 1119

THE COLONY, INC., v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided June 9, 1958.

Attorney(s) appearing for the Case

A. Robert Doll argued the cause for petitioner. With him on the brief were B. H. Barnett and Richard C. Oldham.

Joseph F. Goetten argued the cause for respondent. With him on the brief were Solicitor General Rankin, Assistant Attorney General Rice and Grant W. Wiprud.

MR. JUSTICE HARLAN delivered the opinion of the Court.

The sole question in this case is whether assessments by the Commissioner of two asserted tax deficiencies were barred by the three-year statute of limitations provided in the Internal Revenue Code of 1939.

Under the 1939 Code the general statute of limitations governing the assessment of federal income tax deficiencies is fixed at three years from the date on which the taxpayer filed his return, §...

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