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COMMISSIONER OF INTERNAL REVENUE v. INLAND FINANCE CO.

No. 6925.

63 F.2d 886 (1933)

COMMISSIONER OF INTERNAL REVENUE v. INLAND FINANCE CO.

Circuit Court of Appeals, Ninth Circuit.

February 27, 1933.

Attorney(s) appearing for the Case

G. A. Youngquist, Asst. Atty. Gen., Sewall Key and Morton K. Rothschild, Sp. Assts. to the Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, of Washington, D. C., for petitioner.

G. M. Ferris and B. H. Kizer, both of Spokane, Wash., for respondent.

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

SAWTELLE, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals (23 B. T. A. 199), determining that no tax liability accrued against the taxpayer for the years 1922, 1923, and 1924, under section 213 of the Revenue Acts of 1921 and 1924 (42 Stat. 227, 237, and 43 Stat. 253, 267 [26 USCA § 954 and note]). During these years a number of contracts covering subscriptions to the capital stock of...

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