MINNEHAHA NAT. BANK v. COMMISSIONER OF INTERNAL REVENUE

No. 348.

28 F.2d 763 (1928)

MINNEHAHA NAT. BANK OF SIOUX FALLS, S. D., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

October 13, 1928.


Attorney(s) appearing for the Case

Joe H. Kirby, of Sioux Falls, S. D. (Kirby, Kirby & Kirby, of Sioux Falls, S. D., on the brief), for petitioner.

John Vaughan Groner, Sp. Asst. Atty. Gen. (Mrs. Mabel Walker Willebrandt, Asst. Atty. Gen., Sewell Key, Sp. Asst. Atty. Gen., and C. M. Charest, General Counsel, Bureau of Internal Revenue, and L. W. Scott, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for respondent.

Before STONE and VAN VALKENBURGH, Circuit Judges, and PHILLIPS, District Judge.


PHILLIPS, District Judge.

This is an appeal by the Bank from a decision of the Board of Tax Appeals disallowing a deduction from gross income for the year 1920 of the sum of $25,142.57. In the latter part of 1919, the bank purchased from the bank of Springfield, South Dakota, the three following notes:

  ==============================================
  Maker          |  Amount |  Date    |   Due
  ---------------|---------|----------|---------
  P.D...

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