United States v. Price - 361 U.S. 304 (1960)


U.S. Supreme Court

United States v. Price, 361 U.S. 304 (1960)

United States v. Price

No. 48

Argued December 9, 1959

Decided January 18, 1960

361 U.S. 304

Syllabus

Under § 272(a)(1) of the Internal Revenue Code of 1939, as amended, failure of the Commissioner of Internal Revenue to send to a taxpayer a 90-day notice of a deficiency in his income tax return does not bar an action by the United States to collect such deficiency and statutory interest thereon when the taxpayer had executed and filed, under § 272(d), a waiver of the restrictions of § 272(a) on the assessment and collection of deficiencies, since § 272(d) authorizes the filing of such a waiver "at any time," and not only after the issuance of a 90-day notice of a deficiency. Pp. 361 U. S. 304-313.

263 F.2d 382 reversed.



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