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JACOB BROS. CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 126.

64 F.2d 107 (1933)

JACOB BROS. CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

April 3, 1933.

Attorney(s) appearing for the Case

R. Kemp Slaughter and Hugh C. Bickford, both of Washington, D. C., for petitioner.

G. A. Youngquist, Asst. Atty. Gen., and Sewall Key, and John MacC. Hudson, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and George D. Brabson, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before L. HAND, SWAN, and CHASE, Circuit Judges.

CHASE, Circuit Judge.

The Commissioner of Internal Revenue mailed to Jacob Bros. Company, the petitioner, on March 11, 1926, a deficiency notice in which was included both his determination of a deficiency upon the return filed by the petitioner for the calendar year 1920 and a deficiency upon the return filed by the petitioner for the calendar year 1921. On April 12, 1926, the Commissioner mailed to the petitioner a notice of a deficiency determined upon the return...

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