BURNET v. SAN JOAQUIN FRUIT & INVESTMENT CO.

No. 6346.

52 F.2d 123 (1931)

BURNET, Commissioner of Internal Revenue, v. SAN JOAQUIN FRUIT & INVESTMENT CO.

Circuit Court of Appeals, Ninth Circuit.

June 22, 1931.


Attorney(s) appearing for the Case

G. A. Youngquist, Asst. Atty. Gen., C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, of Washington, D. C., and Sewall Key, John H. McEvers, Helen R. Carloss, and E. C. Crouter, Sp. Assts. to Atty. Gen., for petitioner.

Joseph D. Peeler, of Los Angeles, Cal., and George M. Naus, of San Francisco, Cal. (J. R. Sherrod, of Washington, D. C., of counsel), for respondent.

Before RUDKIN, WILBUR and SAWTELLE, Circuit Judges.


SAWTELLE, Circuit Judge.

This is a petition for review of a decision of the United States Board of Tax Appeals. The facts, as stated in the opinion and findings of the Board, are as follows:

"Under date of July 21, 1925, the Commissioner of Internal Revenue sent a deficiency notice to the San Joaquin Fruit & Investment Company of Tustin, California, the petitioner herein, in which he stated:

"`The determination...

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