Willingham Loan & Trust Co. v. Commissioner

FOSTER, Circuit Judge.

In this case it appears that petitioner kept its books on a monthly basis, taking off trial balances and dividing profits at the end of eaeh month, and closed the books on May 31st annually. However, they filed returns for income and profit taxes on the annual basis for the years 1919, 1920, and .1921, and prior years, using the monthly trial balances for that purpose. The Commissioner of Internal Revenue required returns to be made on the fiscal year basis. This was done; petitioner filing returns on the basis of its fiscal years ending May 31, 1920, and 1921. On March…