Seiberling Rubber Co. v. United States

This is a suit to recover alleged overpayments of income taxes for the years 1948 and 1950, to which plaintiff claims it is entitled as the result of a net operating loss for the year 1949.

The taxpayer, during all times material to this case, kept its books and records and filed its Federal tax returns on *221the accrual method of accounting. In the years prior to 1946 it filed its Federal tax return on a fiscal year basis ending October 31. Since 1946, however, it has filed its Federal tax returns on the calendar year basis.

In 1949, taxpayer paid excess profits tax deficiencies imposed by…