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SECURITY CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 8204.

90 F.2d 951 (1937)

SECURITY CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

June 21, 1937.

Attorney(s) appearing for the Case

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

Robert H. Jackson, Asst. U. S. Atty. Gen., and J. Louis Monarch, Norman D. Keller, Fred W. Dewart, and Warren F. Wattles, Sp. Assts. to the Atty. Gen., for respondent.

Before WILBUR, MATHEWS, and HANEY, Circuit Judges.

HANEY, Circuit Judge.

Petitioner has petitioned this court to review a decision of the Board of Tax Appeals which sustained a deficiency determination of the Commissioner for the years 1927 and 1928, in the amounts of $93,353.10, and $106,111.80.

Petitioner was a corporate affiliate of the Security Trust & Savings Bank, hereinafter referred to as the Bank, throughout the years 1927 and 1928, and consolidated income tax returns were filed for those years...

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