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JOHN M. PARKER CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 5916.

49 F.2d 254 (1931)

JOHN M. PARKER CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

Rehearing Denied May 25, 1931.

Attorney(s) appearing for the Case

John D. Miller, of New Orleans, La., for petitioner.

G. A. Youngquist, Asst. Atty. Gen., and J. P. Jackson, Sp. Asst. to Atty. Gen. (Sewall Key and S. Dee Hanson, Sp. Assts. to Atty. Gen., C. M. Charest, Gen. Counsel, Bureau Internal Revenue, of Washington, D. C., and De Witt M. Evans, Sp. Atty., Bureau Internal Revenue, of Washington, D. C., on the brief), for respondent.

Before BRYAN, SIBLEY, and HUTCHESON, Circuit Judges.

BRYAN, Circuit Judge.

This is a petition by a taxpayer, the John M. Parker Company, to review a decision of the Board of Tax Appeals sustaining a deficiency assessment upon income and profits taxes for the fiscal year ending July 31, 1920. In arriving at that decision, the Board rejected contentions of petitioner (1) that the assessment was barred by the statute of limitations; (2) that it was entitled under sections 200 and 303 of the Revenue Act of 1918 (40 Stat...

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