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SURETY FINANCE CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 7221.

77 F.2d 221 (1935)

SURETY FINANCE CO. OF TACOMA v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

April 29, 1935.

Attorney(s) appearing for the Case

Raymond G. Wright, H. B. Jones, and Robert E. Bronson, all of Seattle, Wash., for petitioner.

Sewall Key and Norman D. Keller, Sp. Assts. to Atty. Gen., for respondent.

Before GARRECHT, Circuit Judge, and NORCROSS, District Judge.

NORCROSS, District Judge.

This is an appeal from a decision of the Board of Tax Appeals upholding a determination of the Commissioner that deficiencies exist in petitioner's income tax returns for the years 1926 and 1927, in the amounts of $296.84 and $254.83, respectively. The Commissioner denied petitioner's right to amortize over its corporate existence the amount of $14,658.69, representing the cost of selling petitioner's capital stock, and the amount of $21...

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