Inverworld, Inc., et al. - Page 117

                                                - 197 -                                                   
            amounts, infra pp. 215-220.                                                                   
                  We conclude that, because LTD filed no returns, it is not                               
            entitled to any deductions for the direct costs in all of LTD's                               
            income categories other than "Interest Income" or for                                         
            compensation expenses for the fees already paid by LTD to INC.                                
            In Blenheim Co. v. Commissioner, supra, the taxpayer, a foreign                               
            corporation, filed a personal holding company surtax return (Form                             
            1120H) but not an income tax return (Form 1120).  The                                         
            Commissioner's "Extended efforts * * * to get * * * [the                                      
            taxpayer] to file a Form 1120 return voluntarily were                                         
            unsuccessful", and the Commissioner was "forced by * * * [the                                 
            taxpayer's] inactivity and uncooperative attitude to prepare a                                
            return for * * * [the taxpayer]".  Id. at 909.  In the return                                 
            that the Commissioner prepared for the taxpayer, the Commissioner                             
            disallowed deductions and credits pursuant to section 233 of the                              
            Revenue Act of 1934.28  The Commissioner then sent a notice of                                
            deficiency to the taxpayer based on that return.  Id.                                         
                  The taxpayer then filed an income tax return (Form 1120)                                
            that included "a breakdown of petitioner's income and claimed                                 
            deductions."  Id.  The Board of Tax Appeals held that the                                     
            circumstances of the case warranted the disallowance of the                                   
            deductions.  The Court of Appeals for the Fourth Circuit                                      
            affirmed, stating that                                                                        


            28                                                                                            
                  Sec. 233 of the Revenue Act was the predecessor statute to                              
            sec. 882(c)(2) of both 1954 I.R.C. and 1986 I.R.C.                                            




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