United States Supreme Court Cases & Opinions

U.S. Supreme Court

National Paper Products Co. v. Helvering, 293 U.S. 183 (1934)

National Paper Products Co. v. Helvering

No. 35

Argued October 17, 1934

Decided November 5, 1934*

293 U.S. 183

Syllabus

Corporations which had filed a consolidated return for a fiscal year ending April 30, 1925, were subjected to an increased rate for the four months following January 1, 1925, by the Revenue Act of 1926, operating retroactively. They filed an additional return merely referring to the net income previously reported and applying the new rate to the part of the income attributable to those four months. Held that the period of limitation against deficiency assessments prescribed by § 277(a)(1) of the 1926 Act began to run from the filing of the first return, and that the second return was an amendment or supplement which did not toll the statute. Zellerbach Paper Co. v. Helvering, ante, p. 293 U. S. 172. P. 293 U. S. 185.

69 F.2d 857 reversed.

Certiorari, 292 U.S. 621, to review Judgments of the court below affirming decisions of the Board of Tax Appeals, 26 B.T.A. 92, sustaining deficiency assessments of income and profits taxes.

Page 293 U. S. 184