Levi Strauss Realty Co. v. United States

March 15,1922, Levi Strauss Realty Company, a corporation, filed with the collector of internal revenue at San Francisco its income and profits tax return for the calendar year 1921, reporting a net income subject to tax in the sum of $48,259.93, upon which there was assessed a tax of $4,825.99. The Commissioner of Internal Revenue reviewed and audited the return and -found and determined that the net income of the taxpayer for the year in question was the sum of $48,259.-93, as reported. The tax thus assessed was paid in installments during the year 1922.

March 15, 1922, Levi Strauss & Company, a corporation, filed with the collector of internal revenue at San Francisco its income and profits tax return for the calendar year 1921, reporting a net loss in the sum of $104,-650.27. The Commissioner of Internal Revenue reviewed and audited this return and found and determined that the loss sustained by the taxpayer was the sum of $323,836.54, instead of $104,650.27 as" claimed.

March 10, 1923, the last-named corporation filed with the collector of internal revenue its income tax retu^i for the calendar year 1922. By this return a tax was reported in the sum of $26,266.27, which was…