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CURRAN v. COMMISSIONER OF INTERNAL REVENUE

No. 8822.

49 F.2d 129 (1931)

CURRAN v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

April 6, 1931.

Attorney(s) appearing for the Case

Bernard J. Thole, of St. Louis, Mo., for appellant.

S. Dee Hanson, Sp. Asst. to Atty. Gen. (G. A. Youngquist, Asst. Atty. Gen., Sewall Key, Sp. Asst. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Allin H. Pierce, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for appellee.

Before STONE and GARDNER, Circuit Judges, and WYMAN, District Judge.

STONE, Circuit Judge.

This is a petition to review a redetermination of the Board of Tax Appeals sustaining a deficiency of $26,876.67 in the individual income taxes of petitioner for the year 1921.

This deficiency assessment results from a payment, by way of credit on indebtedness, which came to petitioner through the form of a dividend declared by the Con P. Curran Printing Company on January 15, 1921. The position of the Commissioner is that the above payment...

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