Blenheim Co. v. Commissioner of Internal Revenue

DOBIE, Circuit Judge:

This is a petition for the review of a decision of the United States Board of Tax Appeals determining a deficiency in petitioner’s income tax liability for the calendar year 1934 in the sum of $1,691.77, and a penalty in the sum of $422.94. The decision of the Board is reported in 1940, 42 B.T.A. 1248.

Petitioner is a foreign corporation organized under the laws of the Colony of Newfoundland. On June 15, 1935, it filed a personal holding company surtax return on Form 1120H, for the calendar year 1934, with the Commissioner of Internal Revenue, at Baltimore, Maryland. This…