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WILDSCHUTZ v. COMMISSIONER OF INTERNAL REVENUE

No. 6729.

60 F.2d 869 (1932)

WILDSCHUTZ v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

September 7, 1932.

Attorney(s) appearing for the Case

Ralph J. Anderson, of Lewistown, Mont. for petitioner.

G. A. Youngquist, Asst. U. S. Atty. Gen., Sewall Key and Norman D. Keller, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, and T. M. Mather, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before WILBUR and SAWTELLE, Circuit Judges, and NORCROSS, District Judge.

WILBUR, Circuit Judge.

The Commissioner redetermined the tax of the petitioner for the year 1922 showing a deficiency in the tax of $1,441.09, resulting from the addition to the income of the petitioner for that year of $12,664.68 as the value of a royalty agreement received in exchange for 784 shares of stock theretofore owned by the petitioner in Green-Wildschutz Royalty Company. The Commissioner fixed the value of this...

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