Guillermo Baez Espinosa - Page 14

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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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