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RETAILERS CREDIT ASS'N v. COMMISSIONER OF INTERNAL REV.

No. 8229.

90 F.2d 47 (1937)

RETAILERS CREDIT ASS'N OF ALAMEDA COUNTY v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

May 10, 1937.

Attorney(s) appearing for the Case

John L. Reith, of Oakland, Cal., for petitioner.

Robert H. Jackson, Asst. Atty. Gen., and Sewall Key, J. Louis Monarch, Howard P. Locke, and Francis I. Howley, Sp. Assts. to the Atty. Gen., for respondent.

Before GARRECHT and HANEY, Circuit Judges, and NETERER, District Judge.

HANEY, Circuit Judge.

By a petition we are asked to review a decision of the Board of Tax Appeals sustaining respondent's determination that petitioner was not exempt from taxation upon its net income for the year 1931.

Petitioner was organized in May, 1917, under title 20, Division 1, part 4 of the Civil Code of California which provided for the organization of co-operative associations to operate on either a profit or non-profit basis. The articles of incorporation...

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