Brooklyn City R.R. v. Commissioner
United States Board of Tax Appeals
Where the taxpayer for many years prior and subsequent to 1921 regularly kept its books of account on the basis of a fiscal year ended June 30, although it made its tax return on the basis of the calendar year, the Commissioner was without authority to compute net income, or to determine a consequent deficiency in tax, for the calendar year 1921. Great West Printing Co.,22 B.T.A. 346, followed.
1Opinion of the Court
opinion.
Trammell:
This is a proceeding for the redetermination of a deficiency in income and profits taxes determined by the respondent for the calendar year 1921 in the amount of $154,227.38. In the “ amended and supplemental petition ” it is alleged that the respondent erred in his determination of the deficiency “ in that he has determined the income and excess profits tax without reference to the established fiscal year of The Brooklyn City Railroad Company and instead of determining the tax for the twelve months ending June 30, 1921, has based his determination upon the return filed by…
2Cases cited2 opinions
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- Easterwood v. CommissionerUnited States Board of Tax Appeals · 1933
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