Ridge L. Harlan and Marjory C. Harlan - Page 17




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               Section 250(d) of the Revenue Act of 1921 (Pub. L. 67-98, 42           
          Stat. 227, 265) reduced the general period of limitations to 4              
          years.                                                                      
               The Revenue Act of 1924 (Pub. L. 68-176, 43 Stat. 253, 299)            
          kept the 4-year general statute of limitations, as section                  
          277(a)(1); it provided that there was no limit in the case of               
          fraud or failure to file a tax return, as section 278(a).                   
               Section 277(a)(1) of the Revenue Act of 1926 (Pub. L. 69-20,           
          44 Stat. 9, 58, 59) reduced the general period of limitations to            
          3 years; the 1926 Act left unchanged the fraud and failure-to-              
          file rule.                                                                  
               Section 275(a) of the Revenue Act of 1928 (Pub. L. 70-562,             
          45 Stat. 791, 856, 857) reduced the general statute of                      
          limitations to 2 years; section 276(a) of the 1928 Act left                 
          unchanged the fraud and failure-to-file rule.  Both of these                
          rules remained unchanged by the Revenue Act of 1932.  Pub. L. 72-           
          154, 47 Stat. 169, 237, 238.                                                
               In what became the Revenue Act of 1934 (Pub. L. 73-216, 48             
          Stat. 680), the House Bill provided (1) that the general statute            
          of limitations be lengthened to 3 years and (2) that the fraud              
          and failure-to-file rule be expanded to apply also to substantial           
          understatements of gross income.  The Ways and Means Committee              
          report (H. Rept. 73-704, pp. 34, 35 (1934), 1939-1 C.B. (Part 2)            
          554, 580) explains these changes as follows:                                






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