Davis Feed Co. v. Commissioner
United States Board of Tax Appeals
The Revenue Act of 1918, approved February 24, 1919, required taxpayers having a fiscal year beginning in 1917 and ending in 1918, who have consistently filed returns on a fiscal year basis, to file a return under its provisions and to pay the tax computed under the provisions of section 205, and the period within which the Commissioner might assess the tax so computed should be reckoned from the date such return was filed.
1Opinion of the Court
*617OPINION.
Littleton:
It is contended by the taxpayer that the Commissioner was prevented by the statute of limitations of five years from assessing and collecting a portion of the deficiency of $3,541.22, for the reason that with respect to seven-twelfths of such tax the statutory period should be reckoned from July 29, 1918, the date of the filing of the return, Form 1031, under the provisions of the Revenue Act of 1916, as amended by the Revenue Act of 1917. The position of the Commissioner is that the date from which the statutory period should be reckoned is the date of filing of the final…
2Cited by5 opinions
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