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CROCKER FIRST NAT. BANK v. COMMISSIONER OF INTERNAL REV.

No. 6692.

59 F.2d 37 (1932)

CROCKER FIRST NAT. BANK OF SAN FRANCISCO v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

May 31, 1932.

Attorney(s) appearing for the Case

Bernhard Knollenberg, of New York City (Morrison, Hohfeld, Foerster, Shuman & Clark, of San Francisco, Cal., and Lord, Day & Lord, of New York City, of counsel), for appellant.

G. A. Youngquist, Asst. Atty. Gen., and Sewall Key and S. Dee Hanson, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, and C. E. Lowery, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before WILBUR and SAWTELLE, Circuit Judges.

WILBUR, Circuit Judge.

This appeal arises on a petition to review the decision and order of the United States Board of Tax Appeals affirming the determination by the Commissioner of Internal Revenue of a deficiency tax of $2,888.08 due from appellant for the year 1926. 22 B. T. A. 1159. The facts were stipulated by the parties and are as follows:

"1. In 1925 a merger of several banks was effected and the petitioner acquired certain banking premises situated...

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