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BURNET v. RIGGS NAT. BANK

No. 3246.

57 F.2d 980 (1932)

BURNET, Commissioner of Internal Revenue, v. RIGGS NAT. BANK.

Circuit Court of Appeals, Fourth Circuit.

April 12, 1932.

Attorney(s) appearing for the Case

Charles E. Lowery, Sp. Atty., Bureau of Internal Revenue, of Washington, D. C. (G. A. Youngquist, Asst. Atty. Gen., Sewall Key and Helen R. Carloss, Sp. Assts. to Atty. Gen., and C. M. Charest, General Counsel, Bureau of Internal Revenue, and Eugene Meachem, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for petitioner.

Paul F. Myers, of Washington, D. C. (Wm. M. Williams, E. B. Quiggle, and Williams, Myers & Quiggle, all of Washington, D. C., on the brief), for respondent.

Before NORTHCOTT and SOPER, Circuit Judges, and HAYES, District Judge.

NORTHCOTT, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals (17 B. T. A. 615), and involves income taxes for the period June 10 to December 31, 1922, in the amount of $6,682.98. The petition is filed by the Commissioner of Internal Revenue, the Board having found in favor of the taxpayer.

The facts, as found by the Board, and as admitted by petitioner, are as follows:

"The...

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