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BESSEMER INV. CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 119.

31 F.2d 248 (1929)

BESSEMER INV. CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

March 4, 1929.

Attorney(s) appearing for the Case

Cotton & Franklin, of New York City (Bernhard Knollenberg and Charles C. Parlin, both of New York City, of counsel), for petitioner.

Mabel Walker Willebrandt, Asst. Atty. Gen., Sewall Key and John Vaughan Groner, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Shelby S. Faulkner, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before MANTON, L. HAND, and AUGUSTUS N. HAND, Circuit Judges.

MANTON, Circuit Judge.

This appeal, taken pursuant to section 1001 (a) of the Revenue Act of 1926 (44 Stat.109 [26 USCA § 1224a]) brings into question the determination of the Commissioner of Internal Revenue in fixing the income tax of the petitioner, a New Jersey corporation, for the taxable years 1918-1919. Petitioner, with other corporations, filed a consolidated return, and the Commissioner determined a deficiency of $11,281.92 for 1918 and $29,124.55 for...

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