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BLACKWELL OIL & GAS CO. v. COMMISSIONER OF INTERNAL REV.

No. 585.

60 F.2d 257 (1932)

BLACKWELL OIL & GAS CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Tenth Circuit.

July 5, 1932.

Attorney(s) appearing for the Case

George C. White, of Cushing, Okl., for petitioner.

Helen R. Carloss, of Washington, D. C., for respondent.

Before PHILLIPS and McDERMOTT, Circuit Judges, and POLLOCK, District Judge.

POLLOCK, District Judge.

This is a petition to review a decision of the Board of Tax Appeals. The Commissioner disallowed two deductions claimed by the taxpayer, one for the year 1923 and the other for 1924, and assessed deficiencies. The Board of Tax Appeals sustained the ruling of the Commissioner.

The facts are:

(1) On January 19, 1923, eighty-six stockholders of the petitioner entered into an option agreement under which they gave one Guiberson...

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