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HELVERING v. ETHEL D. CO.

No. 6038.

70 F.2d 761 (1934)

HELVERING, Commissioner of Internal Revenue, v. ETHEL D. CO.

Court of Appeals of the District of Columbia.

Decided April 9, 1934.

Attorney(s) appearing for the Case

Sewall Key, E. E. Angevine, E. Barrett Prettyman, Shelby S. Faulkner, F. R. Shearer, and Milford S. Zimmerman, all of Washington, D. C., for petitioner.

Robert A. Littleton, of Washington, D. C., and M. K. Wild, of Fresno, Cal., for respondent.

Before MARTIN, Chief Justice, and ROBB, VAN ORSDEL, HITZ, and GRONER, Associate Justices.

GRONER, Associate Justice.

Ethel D. Company is a corporation of California with its principal place of business in San Francisco. It filed in due time its income and profits tax return for the year 1919 in the office of the United States collector at San Francisco. The Commissioner of Internal Revenue determined a deficiency, and on September 26, 1927, duly mailed respondent a notice of the same. The statutory period of limitations expired on March 6, 1925. The Commissioner...

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