United States Board of Tax Appeals February 24, 1932, Docket Nos. 34784, 40646. (Cyclops Iron Works v. Commissioner)

lead-opinion

*605OPINION.

Lansdon :

In respect to the first two years in review the petitioner contends that its taxable status as a trust is fixed, in virtue of - its having filed fiduciary returns for such years, and for 1922, which were accepted and approved by the collector of internal revenue; and that such acceptance constituted a ruling within section 704 (a) of the Revenue Act of 1928,