No. 3130.

50 F.2d 1056 (1931)

MURCHISON NAT. BANK v. GRISSOM, Collector of Internal Revenue.

Circuit Court of Appeals, Fourth Circuit.

June 17, 1931.

Attorney(s) appearing for the Case

James Craig Peacock, of Washington, D. C. (John W. Townsend, of Washington, D. C., on the brief), for appellant.

Lester L. Gibson, Sp. Atty., Bureau of Internal Revenue, of Washington, D. C. (Walter H. Fisher, U. S. Atty., of Clinton, N. C., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, of Washington, D. C., on the brief), for appellee.

Before PARKER and NORTHCOTT, Circuit Judges, and ERNEST F. COCHRAN, District Judge.

NORTHCOTT, Circuit Judge.

The appellant is a national bank organized under the laws of the United States, having its principal office at Wilmington, N. C. During the year 1920, N. P. Sloan & Company, engaged in the cotton business, failed. The company was indebted to appellant at the close of that year in the sum of $91,492.92 on account of loans made to it, against which the bank held as security, cotton in storage, having an estimated value, based upon market...


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