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AMERICAN LAND & INV. CO. v. COM'R OF INTERNAL REVENUE

No. 2892.

40 F.2d 336 (1930)

AMERICAN LAND & INVESTMENT CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

April 28, 1930.

Attorney(s) appearing for the Case

Clement F. Haynsworth, of Greenville, S. C. (Haynsworth & Haynsworth, of Greenville, S. C., on the brief), for petitioner.

Andrew D. Sharpe, Sp. Asst. to Atty. Gen. (Sewall Key, Sp. Asst. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and John McC. Hudson, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief) for respondent.

Before WADDILL and NORTHCOTT, Circuit Judges, and GLENN, District Judge.

GLENN, District Judge.

This is a petition to review the decision of the United States Board of Tax Appeals. The only previous opinion in the case is that of the Board reported in 14 B. T. A. 615. The matter was heard by the Board on an agreed stipulation of facts. This agreed stipulation of facts had been prepared by an accountant, and it fails to show the exact nature of a contract covering the sale of land out of which the income involved came. The transaction out...

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