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WATSON v. COMMISSIONER OF INTERNAL REVENUE

No. 6911.

62 F.2d 35 (1932)

WATSON v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

December 5, 1932.

Attorney(s) appearing for the Case

F. C. Drumm, of Santa Ana, Cal., and Daniel Dougherty, of Los Angeles, Cal., for petitioner.

G. A. Youngquist, Asst. Atty. Gen., and Sewall Key and Wm. Cutler Thompson, Sp. Asst. to the Atty. Gen. (C. M. Charest, Gen. Counsel, and Arthur Carnduff, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

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

CAVANAH, District Judge.

The Board of Tax Appeals decided that there was a profit of $79,259.39 realized by the petitioner during the year 1924 from the alleged sale of a bus line and that there was a deficiency in the federal income tax of petitioner in the sum of $6,389.02, and a review of that decision is presented to this court.

The issue presented is whether the board erred in construing a certain written instrument executed by the petitioner and the...

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