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COMMISSIONER OF INTERNAL REVENUE v. R. J. DARNELL INC.

No. 5900.

60 F.2d 82 (1932)

COMMISSIONER OF INTERNAL REVENUE v. R. J. DARNELL, Inc.

Circuit Court of Appeals, Sixth Circuit.

June 29, 1932.

Attorney(s) appearing for the Case

Morton K. Rothschild, of Washington, D. C. (G. A. Youngquist, Asst. Atty. Gen., and Sewall Key, C. M. Charest, and Arthur Carnduff, all of Washington, D. C., on the brief), for petitioner.

B. H. Saunders, of Washington, D. C. (Charles D. Hamel, of Washington, D. C., Frank M. Gilliland, of Memphis, Tenn., and Hamel, Park & Saunders and Edward M. Woolf, all of Washington, D. C., on the brief), for respondent.

Before HICKS, HICKENLOOPER, and SIMONS, Circuit Judges.

HICKENLOOPER, Circuit Judge.

Prior to January 26, 1920, respondent owned and operated a sawmill and timber properties in Panola county, Miss. On the date mentioned it entered into a contract for the sale of the sawmill and equipment for the base price of $225,000, payable, $25,000 on the signing of the contract and $50,000 on delivery of warranty deeds, and by the delivery of three notes respectively for $25,000, $50,000, and $75,000, and maturing six months, one...

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