Joy Floral Co. v. Commissioner

MARTIN, Chief Justice.

The decision involved in this appeal is reported at 7 B. T. A. 800. The facts in the ease are undisputed, and present but a single well-defined question of law.

The taxes in controversy are for the fiscal year ending July 31,1919, and accrued under the Revenue Act of 1918 (40 Stat. 1057). The taxpayer’s return was made on October 15, 1919, and the deficiency assessment in question was not made until July 15, 1925. The taxpayer contends that the Commissioner possessed no lawful authority to make the assessment after the lapse of five years after the filing of the return,…