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ZELLERBACH CO. v. HELVERING

Nos. 37 and 38.

293 U.S. 172 (1934)

55 S.Ct. 127

79 L.Ed. 264

ZELLERBACH PAPER CO. v. HELVERING, COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided November 5, 1934.

Attorney(s) appearing for the Case

Mr. John Francis Neylan, with whom Mr. J. Paul Miller was on the brief, for petitioners.

Assistant to the Attorney General Stanley, with whom Solicitor General Biggs, Assistant Attorney General Wideman, and Mr. James W. Morris were on the brief, for respondent.

MR. JUSTICE CARDOZO delivered the opinion of the Court.

The controversy in these cases hinges upon the date when the statute of limitations began to run against deficiency assessments by the Commissioner of Internal Revenue.

On July 16, 1921, Zellerbach Paper Company filed a consolidated income and profits tax return in behalf of itself and a subsidiary, National Paper Products Company, for the fiscal year beginning...

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