HARRIMAN NATIONAL BANK v. COM'R OF INTERNAL REVENUE

No. 372.

43 F.2d 950 (1930)

HARRIMAN NATIONAL BANK, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

Circuit Court of Appeals, Second Circuit.

August 4, 1930.


Attorney(s) appearing for the Case

Cotton, Franklin, Wright & Gordon, of New York City (Boykin C. Wright and Charles C. Parlin, both of New York City, of counsel), for petitioner.

G. A. Youngquist, Asst. Atty. Gen., J. Louis Monarch, Sp. Asst. to Atty. Gen., and Dean P. Kimball, Sp. Atty., Bureau of Internal Revenue, of Washington, D. C. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, of Washington, D. C., of counsel), for respondent.

Before MANTON, L. HAND, and SWAN, Circuit Judges.


SWAN, Circuit Judge.

The opinion below, reported in 14 B. T. A. 743, states that the sole question presented to the Board was whether the bank was a dealer in securities during the taxable years under review, and as such entitled to return its income on the basis of inventories of its securities. The Commissioner had denied it the use of inventories, resulting in the imposition of deficiencies in taxes aggregating some $220,000. The Board of Tax Appeals confirmed...

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