HAGGAR COMPANY v. HELVERING, COMMISSIONER OF INTERNAL REVENUE, 308 U.S. 389

Summary

Section 215 of the Act required corporate taxpayers to declare the value of its capital stock. However, because the declared value for the first year was a controlling factor for the computation of taxes for later years, § 215 provided that the declaration once made could not be amended. The corporate taxpayer timely filed its return but made a mistake in the computation of the value of its capital stock. After learning of the mistake, the taxpayer prepared an amended return and filed it within the deadline for filing § 215 returns. The IRS rejected the amended return and assessed a deficiency against the taxpayer. The lower appellate court upheld the deficiency. The court reversed the deficiency. The court held that a capital stock tax return filed pursuant to § 215 of the Act may be amended within the time fixed for filing the return. The court stated that the term "first return," for purposes of § 215, meant a return for the first year in which the taxpayer exercised the privilege ...