PERATA v. COMMISSIONER OF INTERNAL REVENUE

No. 8197.

89 F.2d 550 (1937)

PERATA v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

April 13, 1937.


Attorney(s) appearing for the Case

Leo J. McEnerney, of San Francisco, Cal. (J. Bruce Fratis, of San Francisco, Cal., of counsel), for petitioner.

Robert H. Jackson, Asst. U. S. Atty. Gen., and Sewall Key, J. Louis Monarch, Warren F. Wattles, and Frederick W. Dewart, Sp. Assts. to the Atty. Gen., for respondent.

Before WILBUR, MATHEWS, and HANEY, Circuit Judges.


HANEY, Circuit Judge.

This court is asked to review a decision of the Board of Tax Appeals determining a deficiency in the income tax of petitioner, by the petition presented.

The Italo Petroleum Corporation of America, hereinafter referred to as Italo, in 1928 entered into agreements with certain oil companies to purchase the assets of such companies. These agreements were entered into either in the name, of Italo or one Myers, its agent. In the aggregate...

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