§235

Accordingly we hold that petitioner is entitled to the deduction of the expenses as set out in the above tabulation and that respondent erred in computing petitioner’s taxes on the basis of its gross income.

Section 235 of the Revenue Act of 1928 provided: SEC. 235. RETURNS. In the case of a foreign corporation not having any office or place of business in the United States the return, in lieu of the time prescribed in section 53(a)(1), shall be made on or before the fifteenth day of the sixth month following the close of the fiscal year, or, if the re

A spouse Tier 2 benefit is computed as 45% of the railroad employee’s Tier 2 benefit. See 20 C.F.R. § 226.32 (2016). 5 We note that the Social Security Administration (SSA) is responsible for the determination of the amount of Social Security benefits to be paid by the RRB. See 20 C.F.R. § 235.4 (2016). 5 [*5] The RRB also issued M

In the Commissioner’s view, this “means that deductions are allowable only when returns are filed within the time specified in section 235 of the Revenue Acts of 1928 and 1932.” Ibid.

examination of the records of the licensee or of any other inquiry or investigation, .that the correct amount of the tax is greater, than that shown on .the return, or that any tax imposed by this chapter has not been paid, an assessment of such tax may be made, in the manner provided in-section 235-108(b) .

- 13 - be filed timely within the meaning of section 235 (currently section 6072(c)).