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CENTRAL LIFE ASSUR. SOC., MUT. v. COM'R OF INTERNAL REVENUE

No. 9134.

51 F.2d 939 (1931)

CENTRAL LIFE ASSUR. SOC., MUT., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

July 13, 1931.

Attorney(s) appearing for the Case

Donald Evans, of Des Moines, Iowa (Richard S. Doyle, Charles D. Hamel and John Enrietto, all of Washington, D. C., Carr, Cox, Evans & Riley, of Des Moines, Iowa, and Hamel, Doyle, Park & Saunders, of Washington, D. C., on the brief), for petitioner.

A. G. Divet, 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 R. N. Shaw, 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.

STONE, Circuit Judge.

This is a petition to review an order of the Board of Tax Appeals sustaining the Commissioner in the redetermination of deficiencies in the taxes of the petitioner for the taxable years 1921 and 1923 to 1926, inclusive.

The petitioner presents here but one issue. That issue is whether the income covered by these deficiency assessments was truly the income of the petitioner, or was income of stockholders in a stock insurance company which...

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