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BELRIDGE OIL CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 8114.

85 F.2d 762 (1936)

BELRIDGE OIL CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

September 21, 1936.

Attorney(s) appearing for the Case

Claude I. Parker, John B. Milliken, and Bayley Kohlmeier, all of Los Angeles, Cal. (Llewellyn A. Luce, of Washington, D. C., of counsel), for petitioner.

Robert H. Jackson, Asst. Atty. Gen., and Sewall Key and Robert N. Anderson, Sp. Assts. to Atty. Gen., for respondent.

Before WILBUR, GARRECHT, and DENMAN, Circuit Judges.

GARRECHT, Circuit Judge.

A petition to review a decision of the Board of Tax Appeals in this proceeding was heretofore heard by this court and at that time a per curiam opinion was rendered. See 69 F.2d 432, 433. The Board of Tax Appeals was directed to find specifically the actual value of the option involved at the time it was transferred to petitioner. In that connection, among other things, the court said:

"If the sum...

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