United States Board of Tax Appeals October 16, 1928, Docket No. 12941 (United States Trust Co. v. Commissioner)

*1076OPINION.

Phillips:

This proceeding was submitted on a stipulation of the facts which have been adopted as our findings of fact. The stipulation was supplemented by testimony which established that the New York State franchise tax on trust companies accrues rateably over the year, although not payable until after its close.