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the claimed deductions. The Board distinguished Anglo-American
Direct Tea Trading Co. v. Commissioner, supra, on the grounds
that in Anglo-American the returns prepared by the revenue agent
were never accepted by the Commissioner, the taxpayer's
delinquent returns were audited (not the returns prepared by the
revenue agent), and the returns were filed by the taxpayer before
the notice of deficiency was issued. Taylor Sec., Inc. v.
Commissioner, supra at 702-703.
A year later in Blenheim Co. v. Commissioner, 42 B.T.A.
1248, 1251 (1940), affd. 125 F.2d 906 (4th Cir. 1942), the Board
followed Taylor Sec., Inc. v. Commissioner, supra, where a
foreign corporation filed a timely personal holding company
return (Form 1120H) for the taxable year 1934, but failed to file
a corporate income tax return (Form 1120). The only income shown
on the Form 1120H consisted of dividends received from domestic
corporations. The Commissioner notified the corporation that a
Form 1120 had not been filed on its behalf and requested that it
be filed. The secretary of the corporation ignored these
requests because he believed the Form 1120H contained all the
information required to compute the corporation's tax liability.
In addition, he believed the corporation was not required to file
a Form 1120 since, at that time, dividends received from a
domestic corporation were not subject to Federal income tax. The
Commissioner subsequently prepared a return for the corporation
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