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BONDED MORTGAGE CO. v. COMMISSIONER OF INT. REV.

No. 3560.

70 F.2d 341 (1934)

BONDED MORTGAGE CO. OF BALTIMORE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

April 3, 1934.

Attorney(s) appearing for the Case

Reuben Oppenheimer and John H. Skeen, both of Baltimore, Md. (Bernard R. Youngman, of Baltimore, Md., on the brief), for petitioner.

Morton K. Rothschild, Sp. Asst. to Atty. Gen. (Frank J. Wideman, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for respondent.

Before PARKER and SOPER, Circuit Judges, and CHESNUT, District Judge.

CHESNUT, District Judge.

The question presented by this petition to review the decision of the United States Board of Tax Appeals involves the proper income tax accounting of the Bonded Mortgage Company of Baltimore, a Maryland corporation, for its fiscal years ending June 30, 1926 and 1927, and raised under the Revenue Act of 1926 (44 Stat. 9).

As its name indicates, the taxpayer was engaged in the business of loaning money on mortgage security and selling...

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