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FINANCE SEC. CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 6950.

69 F.2d 829 (1934)

FINANCE SEC. CO., Inc., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

March 21, 1934.

Attorney(s) appearing for the Case

Albert A. Jones, of Washington, D. C., and Bascom D. Talley, of Bogalusa, La., for petitioner.

Frank J. Wideman, Asst. Atty. Gen., Sewall Key and Norman D. Keller, Sp. Asst. Attys. Gen., and E. Barrett Prettyman, Gen. Counsel, Bureau of Internal Revenue, and F. B. Schlosser, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before BRYAN, FOSTER, and HUTCHESON, Circuit Judges.

FOSTER, Circuit Judge.

The petitioner is engaged in the business of financing installment purchases of automobiles, buying the notes for the deferred payments. The Commissioner determined deficiencies of income taxes for the years 1927 and 1928 of respectively $848.60 and $614.73. On appeal to the Board of Tax Appeals the ruling of the Commissioner was approved. The facts were stipulated but appear only in the opinion of the Board which is not reported. Only two items...

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