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FARMVILLE OIL & FERTILIZER CO. v. COMMISSIONER OF INT. REV.

No. 3826.

78 F.2d 83 (1935)

FARMVILLE OIL & FERTILIZER CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

June 3, 1935.

Attorney(s) appearing for the Case

Alfons B. Landa, of Washington, D. C. (Joseph E. Davies, Raymond N. Beebe, Seth W. Richardson, and Davies, Beebe, Busick & Richardson, all of Washington, D. C., on the brief), for petitioner.

Morgan V. Martin, Sp. Asst. to the Atty. Gen. (Frank J. Wideman, Asst. Atty. Gen., and Sewall Key and J. P. Jackson, Sp. Assts. to the Atty. Gen., on the brief), for respondent.

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

SOPER, Circuit Judge.

The Board of Tax Appeals affirmed a determination by the Commissioner of Internal Revenue of a deficiency of $1,885.97 in the income of the taxpayer for the fiscal year ending July 31, 1930; and this conclusion is assailed on the ground that the Commissioner disallowed a deduction from gross income of $20,859.70 out of $21,545.42 claimed as a reserve for "inactive contingencies." The taxpayer contends that the deduction should have been allowed...

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