Jackson Iron & Steel Co. v. Commissioner

HICKENLOOPER, Circuit Judge.

With its tax return for the year 1918 petitioner filed an application for special relief under sections 327 and 328 of the Revenue Act of 1918, e. 18, 40 Stat. 1057, 1093. While it had estimated its tax at $174,500 in its tentative return filed March 13, 1919, the complete return filed June 14, 1919, showed taxes payable in the sum of $235,646.33 in the event that special relief was not granted; and the application for such relief which accompanied this return assumed that by virtue of such application alone the initial computation of the tax was to be upon the…