WHALEY, Judge.
For the year 1920 the plaintiff filed its income tax return on a calendar year basis on March 15, 1921, and showed a tax due of $2,747.22 which was paid. Subsequently the Commissioner of Internal Revenue determined that from September 30, 1918, the plaintiff should have returned its income on a fiscal year basis ending September 30 of each year. On November 30, 1925, he sent the so-called "60-day letter" advising plaintiff of his determination which...
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