Fred T. Ley & Co. v. Commissioner
United States Board of Tax Appeals
Petitioner made and filed an income and profits-tax return on June 15, 1921, for its fiscal year ended February 28, 1921, which was not false or fraudulent with intent to evade the tax. Petitioner was not liable for an additional tax for such taxable year after the enactment of the Revenue Act of 1921 by reason of any change in the law.
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Petitioner made and filed an income and profits-tax return on June 15, 1921, for its fiscal year ended February 28, 1921, which was not false or fraudulent with intent to evade the tax. Petitioner was not liable for an additional tax for such taxable year after the enactment of the Revenue Act of 1921 by reason of any change in the law. Held that the return filed on June 15, 1921, was a legal return for the taxable year under the law and regulations, and operated to start the running of the statute of limitation of four years. Held, further, that since the deficiency notice for the taxable…
1Opinion of the Court
*750OPINION.
Littleton :
Section 227 (a) of the Revenue Act of 1918 provides “That returns shall be made on or before the fifteenth day of the third month following the close of the fiscal year,” and section 241 (a) of that Act provides “That returns of corporations shall be made at the same time as is provided in subdivision (a) of section 227.” Sections 227 (a) and 241 (a) of the Revenue Act of 1921, approved November 23, 1921, and effective from January 1, 1921, were identical with the provisions of those sections of the Revenue Act of 1918. On March 16, 1922, Treasury Decision 3305, signed by…
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