HELVERING v. WASHBURN

No. 11250.

99 F.2d 478 (1938)

HELVERING, Com'r of Internal Revenue, v. WASHBURN.

Circuit Court of Appeals, Eighth Circuit.

October 21, 1938.


Attorney(s) appearing for the Case

S. Dee Hanson, Sp. Asst. to Atty. Gen. (James W. Morris, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for petitioner.

Leland W. Scott, of Minneapolis, Minn. (John W. Windhorst and Junell, Fletcher, Dorsey, Barker & Colman, all of Minneapolis, Minn., on the brief), for respondent.

Before GARDNER, SANBORN, and BOOTH, Circuit Judges.


GARDNER, Circuit Judge.

This is a petition to review a decision of the United States Board of Tax Appeals involving alleged deficiency in income tax for 1933. The question presented for decision is whether South Texas Syndicate, of which A. McC. Washburn is trustee, is an association taxable as a corporation within the meaning of Section 1111(a) (2) of the Revenue Act of 1932, 26 U.S.C.A. § 1696 (3), for the calendar year 1933.

In 1900, Jed L. Washburn...

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