United States v. Oklahoma Natural Gas Company, a Corporation

BRATTON, Circuit Judge.

The question upon which this case turns is the date on which a taxpayer in Oklahoma which keeps its books and files its federal income tax returns on a fiscal year accrual basis may accrue for federal income tax purposes ad valorem taxes levied on its personal and real property pursuant to state law.

Oklahoma Natural Gas Company, hereinafter referred to as the taxpayer, is engaged in the production and distribution of natural gas in Oklahoma; and it keeps its books and files its income tax returns on a fiscal year accrual basis. Its fiscal year commences September 1 and…