price
argued
december
decided
january
internal
revenue
code
amended
failure
commissioner
internal
revenue
send
taxpayer
notice
deficiency
income
tax
return
bar
action
collect
deficiency
statutory
interest
thereon
taxpayer
executed
filed
waiver
restrictions
assessment
collection
deficiencies
since
authorizes
filing
waiver
time
issuance
notice
deficiency
pp
reversed
howard
heffron
argued
cause
brief
solicitor
general
rankin
assistant
attorney
general
rice
prescott
george
lynch
lee
mclane
argued
cause
filed
brief
respondent
justice
harlan
delivered
opinion
brought
action
respondent
taxpayer
collection
deficiency
taxes
year
statutory
interest
thereon
respondent
defended
ground
action
maintained
commissioner
internal
revenue
never
issued
taxpayer
notice
deficiency
commonly
known
letter
amount
question
defense
based
internal
revenue
code
stat
amended
providing
pertinent
part
follows
case
taxpayer
commissioner
determines
deficiency
respect
tax
imposed
chapter
commissioner
authorized
send
notice
deficiency
taxpayer
registered
mail
within
ninety
days
notice
mailed
taxpayer
may
file
petition
tax
redetermination
deficiency
assessment
deficiency
respect
tax
imposed
chapter
distraint
proceeding
collection
shall
made
begun
prosecuted
notice
mailed
taxpayer
expiration
period
petition
filed
tax
decision
tax
become
final
taxpayer
shall
time
right
signed
notice
writing
filed
commissioner
waive
restrictions
provided
subsection
section
assessment
collection
whole
part
deficiency
start
language
terms
right
waiver
available
time
applicable
restrictions
contained
restrictions
include
prohibitions
assessment
collection
deficiency
prior
mailing
letter
less
prohibitions
relating
period
following
issuance
letter
petition
redetermination
deficiency
may
filed
awaiting
decision
tax
respondent
seeks
support
view
provisions
read
applying
period
following
issuance
letter
noting
limited
waivers
restrictions
assessment
collection
deficiency
asserting
deficiency
come
existence
letter
mailed
reading
statute
said
follow
first
sentence
case
taxpayer
commissioner
determines
deficiency
respect
tax
imposed
chapter
commissioner
authorized
send
notice
deficiency
taxpayer
registered
mail
section
face
therefore
support
view
waiver
restrictions
assessment
collection
tax
effective
filed
issuance
letter
think
similar
conclusion
follows
examination
legislative
history
relevant
statutory
enactments
creating
tax
originally
known
board
tax
appeals
congress
provided
forum
taxpayers
obtain
independent
review
commissioner
internal
revenue
determination
additional
income
taxes
board
advance
paying
tax
found
commissioner
due
old
colony
trust
commissioner
section
revenue
act
stat
revenue
act
stat
predecessors
code
disabled
commissioner
assessing
collecting
deficiency
notice
deficiency
issued
later
amended
days
thereafter
event
taxpayer
took
appeal
board
tax
appeals
within
period
body
rendered
final
decision
however
even
though
taxpayer
wish
contest
commissioner
determination
deficiency
board
interest
deficiency
continued
accrue
original
due
date
tax
time
seeking
board
review
run
interest
thereafter
collectible
upon
assessment
tax
revenue
act
stat
meet
situation
revenue
act
added
stat
waiver
provisions
code
time
congress
provided
predecessor
code
filing
waiver
provided
subsection
stop
running
interest
deficiency
upon
expiration
days
filing
upon
assessment
deficiency
whichever
earlier
relation
two
sections
act
comparable
sections
code
well
clear
waiver
provided
code
order
permit
taxpayer
pay
tax
stop
running
interest
commissioner
thereupon
permitted
assess
collect
tax
free
restrictions
contained
code
taxpayer
protected
continued
running
interest
due
delay
assessment
cutoff
provided
code
find
history
purpose
discloses
warrant
inferring
intended
taxpayer
without
power
stop
running
interest
formal
notice
deficiency
issued
yet
appear
necessary
effect
respondent
position
major
reliance
placed
passage
senate
committee
report
act
order
permit
taxpayer
pay
tax
stop
running
interest
committee
recommends
section
bill
taxpayer
time
permitted
waive
writing
restrictions
commissioner
assessing
collecting
tax
without
taking
away
right
taxpayer
take
case
board
think
subsequent
legislative
developments
change
view
statute
several
years
enactment
statute
appeals
ninth
circuit
expressed
views
similar
formed
basis
decision
mutual
lumber
poe
mccarthy
commissioner
congress
considered
various
suggested
revisions
revenue
statutes
house
representatives
subcommittee
recommended
express
repudiation
decisions
recommendation
adopted
failure
act
respondent
us
infer
acceptance
congress
ninth
circuit
position
congress
affords
dubious
foundation
drawing
positive
inferences
moreover
subcommittee
discussion
set
full
margin
support
meaning
sought
derived
certain
isolated
passages
read
taken
whole
subcommittee
said
appears
us
espouse
position
commissioner
interpretation
statute
correct
clarification
called
doubts
caused
ninth
circuit
decisions
declined
review
whether
congress
thought
proposal
unwise
respondent
argues
unnecessary
tell
accordingly
inference
properly
drawn
failure
congress
act
finally
similarly
unable
find
support
respondent
position
history
code
recodification
settled
taxable
years
covered
act
question
us
expressly
authorizing
waiver
prior
issuance
letter
reports
contain
clear
statement
congress
view
existing
law
light
however
tends
favor
government
contentions
new
statute
amended
another
subsection
section
containing
waiver
provision
reports
refer
amendment
material
change
existing
law
respondent
argues
change
regarding
waiver
probably
thought
material
inferences
legislative
history
rest
slender
reed
moreover
views
subsequent
congress
form
hazardous
basis
inferring
intent
earlier
one
see
mine
workers
legislative
history
call
result
contrary
indicated
language
act
hold
waiver
given
pursuant
internal
revenue
code
predecessor
sections
although
executed
prior
issuance
notice
deficiency
fully
effective
instrument
reversed
remanded
footnotes
associated
mutuals
delaney
moore
cleveland
see
also
roos
cl
supp
see
moore
cleveland
supra
analyzing
code
stat
defining
deficiency
section
code
stat
respects
material
identical
counterpart
provided
pertinent
part
interest
upon
amount
determined
deficiency
shall
assessed
time
deficiency
shall
paid
upon
notice
demand
collector
shall
collected
part
tax
rate
per
centum
per
annum
date
prescribed
payment
tax
date
deficiency
assessed
case
waiver
section
thirtieth
day
filing
waiver
date
deficiency
assessed
whichever
earlier
see
moore
cleveland
supra
associated
mutuals
delaney
supra
even
respondent
interpretation
passage
however
give
literal
effect
language
taxpayer
time
permitted
waive
restrictions
assessment
collection
deficiency
issuance
notice
deficiency
order
enable
government
collect
admitted
deficiencies
orderly
expeditious
manner
without
delay
necessarily
involved
issuance
formal
notice
deficiency
also
enable
taxpayers
curtail
interest
period
deficiencies
permitting
government
make
earlier
assessment
tax
otherwise
possible
bureau
internal
revenue
entered
cooperative
agreements
taxpayers
practice
long
standing
bureau
endeavor
secure
signed
agreement
taxpayer
additional
taxes
proposed
agent
result
field
investigation
also
taxes
proposed
letters
commissioner
mailed
preliminaries
issuance
formal
notice
deficiency
authorized
section
revenue
act
corresponding
provisions
prior
acts
practice
regard
signed
agreement
valid
waiver
section
revenue
act
corresponding
provisions
prior
acts
purpose
computing
interest
deficiencies
agreed
accordance
section
revenue
act
corresponding
provisions
prior
acts
interest
deficiency
agreed
computed
date
assessment
thirtieth
day
filing
agreement
whichever
earlier
great
majority
cases
assessment
made
within
days
agreement
procured
thereby
making
collection
deficiencies
nearly
concurrent
discovery
case
formal
notice
required
given
result
two
decisions
circuit
appeals
ninth
circuit
mutual
lumber
poe
certiorari
denied
mccarthy
commissioner
certiorari
denied
apr
valid
waiver
given
taxpayer
prior
formal
determination
commissioner
evidenced
letter
deficiency
tax
subcommittee
feeling
language
statute
already
sufficiently
clear
feels
compelled
view
action
denying
certiorari
recommend
recommendation
amendment
inserted
insure
validity
waivers
given
mailing
deficiency
letter
amendment
provide
taxpayer
shall
right
time
deficiency
proposed
manner
commissioner
may
direct
whether
sending
notice
deficiency
provided
subsection
section
waive
signed
notice
writing
restrictions
conditions
however
imposed
immediate
assessment
collection
whole
part
deficiency
proposed
believed
proposed
amendment
furnish
clear
unquestionable
statutory
basis
satisfactorily
functioning
departmental
procedure
conducive
early
settlement
controverted
issues
without
necessity
litigation
time
retaining
taxpayer
present
privilege
paying
deficiencies
appeal
thereby
terminating
running
deficiency
interest
report
subcommittee
house
committee
ways
means
proposed
revision
revenue
laws
pp
section
code
reads
follows
taxpayer
shall
time
whether
notice
deficiency
issued
right
signed
notice
writing
filed
secretary
delegate
waive
restrictions
provided
subsection
assessment
collection
whole
part
deficiency
section
restrictions
applicable
deficiencies
petition
tax
material
change
existing
law
made
subsection
section
contains
new
provision
providing
amount
paid
tax
respect
tax
may
assessed
upon
receipt
payment
notwithstanding
restrictions
assessment
contained
subsection
see
also
effect
justice
douglas
justice
stewart
joins
dissenting
mutual
lumber
poe
decided
view
correct
rule
one
early
criticized
challenged
yet
one
congress
undertake
change
therefore
affirm
judgment