United States Board of Tax Appeals March 6, 1941, Docket No. 97674. (Red Wing Potteries, Inc. v. Commissioner)

lead-opinion

*842OPINION.

Keen :

Petitioner was on the accrual basis and the primary question is whether all the circumstances which fix its liability for the tax had occurred in a year before 1936, when the tax was paid and the deduction for it claimed. The alternative question of recoupment must wait our answer on this.