Wm. B. Scaife & Sons Co. v. Commissioner

BIGGS, Circuit Judge.

In June, 1936, the petitioner’s vice president in charge of tax matters, instructed its treasurer to make its capital stock tax return as required by Section 105 of the Revenue Act of 1935, c. 829, 49 Stat. 1017, 26 U.S.C.A. Int.Rev.Acts, page 796, and to place upon its stock a value of $1,000,-000. On July 29, 1936 the treasurer filed the return and by mistake placed a value of $600,000 upon the stock. When this error was discovered, a correct return was prepared declaring the value of the stock to be $1,000,000, and on September 3, 1936, which was after the time…