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PLANTERS' OPERATING CO. v. COMMISSIONER OF INT. REVENUE

No. 8789.

55 F.2d 583 (1932)

PLANTERS' OPERATING CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

January 25, 1932.

Attorney(s) appearing for the Case

Phil D. Morelock, of Kansas City, Mo. (Perry W. Shrader, of Kansas City, Mo., Dudley Doolittle, of Strong, Kan., Llewellyn A. Luce, of Washington, D. C., and Walsh & Aylward and Shouse, Doolittle, Morelock & Shrader, all of Kansas City, Mo., on the brief), for appellant.

Helen R. Carloss, 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 Dean P. Kimball, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for appellee.

Before VAN VALKENBURGH, BOOTH, and GARDNER, Circuit Judges.

BOOTH, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals which affirmed the holding of the Commissioner of Internal Revenue in refusing to assign any value to a lease of certain hotel property in St. Louis, Mo.

The case involves income and profits taxes for the years 1919 and 1920, and income taxes for the years 1919 to 1922.

The main undisputed facts are briefly as follows: In 1918, the Planters' Operating

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