William O. Douglas,
Scaife Company v. Commissioner of Internal Revenue…
“ The return must be made within one month after the close of the year with respect to which the tax is imposed. § 105 (d) . While the Commissioner by rules and regulations 'may extend the time for making' the return, no extension shall be for more than sixty days. § 105 (d) . Under Art. 37 (b) of Treasury Regulations 64 (1936 ed.) an extension of time for filing the return and paying the tax shall be granted only upon written application under oath filed on or before the statutory due date and on a showing of reasonable cause for an extension. Petitioner sought no such extension. ”
