Theriot v. Commissioner of Internal Revenue

RIVES, Circuit Judge.

This appeal involves deficiencies in income taxes in the amounts of $1,810.56 and $17,137.33 for the years 1943 and 1945, re-spéctively.

Prior to her marriage to Romeal Theriot on November 25, 1942, the taxpayer had been employed as a stenographer and earned $1,217.27 during 1942. She had always filed her income tax returns on the calendar year basis. After continuing to use that basis for 1942 and 1943, the taxpayer discovered that if she had used the basis of the fiscal year on which her husband reported, her forgiveness benefits under Section 6 of the Current Tax…