Woodward Iron Company v. United States

GOLDBERG, Circuit Judge:

“A paradox, a paradox,

A most ingenious paradox!” 1

The taxpayer, through 1953 consistent in its ratable deductions of state ad valorem taxes, reads a 1954 statute as automatically transmuting it into taking lump sum deductions while urging that the congressional intent of the statute was to accommodate change from lump sum to ratable methods.

The taxpayer owns property in Alabama, in which state ad valorem taxes are assessed and collected on the basis of a fiscal year beginning October 1 and ending September 30. During the years in question the taxpayer used the calendar…