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PIONEER COOPERAGE CO. v. COMMISSIONER OF INT. REV.

No. 9030.

53 F.2d 43 (1931)

PIONEER COOPERAGE CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

September 29, 1931.

Attorney(s) appearing for the Case

Richard S. Doyle and Marion N. Fisher, both of Washington, D. C. (A. S. Johnston, of Lincoln, Neb., and Charles D. Hamel, of Washington, D. C., on the brief), for petitioner.

G. A. Youngquist, Asst. Atty. Gen. (Sewall Key and Norman D. Keller, Sp. Assts. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Dean P. Kimball, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for respondent.

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

MARTINEAU, District Judge.

This is a petition to review an order of the Board of Tax Appeals and involves a construction of section 234 (a) (4) of the Revenue Act of 1918 (40 Stat. 1077), allowing to a corporation deductions for "losses sustained during the taxable year and not compensated for by insurance or otherwise."

The facts are not in dispute. Several years prior to 1913, petitioner, a corporation engaged in...

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