J. M. Perry & Co. v. Commissioner Internal

The Commissioner of Internal Revenue determined that the petitioner-taxpayer was subject to additional taxes for the years 1935 and 1936, as imposed by Section 102 of the Revenue Acts of 1934 and 1936 [c. 277, 48 Stat. 680, 26 U.S.C.A. Int. Rev. Acts, page 690; c. 690, 49 Stat. 1648, 26 U.S.C.A. Int. Rev. Acts, page 851]. The Board of Tax Appeals sustained the determination of the Commissioner, and the taxpayer seeks a reversal.