Parks-Chambers, Inc. v. Commissioner of Internal Revenue

HUTCHESON, Circuit Judge.

What is for decision here is whether the Board erred in holding: (1) That for 1936, the tax year in question, petitioner could not, as it had been doing since its organiza*66tion, use a fiscal year based on a day in January other than the last, but must use a calendar year; and (2) that therefore it was not entitled to a dividends paid credit of the whole or an allocated part, 340/365ths, of a dividend of $30,000, it had declared and paid on January 25, 1937.

The facts as stipulated are fully set out in the findings and opinion of the Board,1 and we need not repeat them…