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SOUTH ALABAMA LAND CO. v. COMMISSIONER OF INT. REV.

No. 9052.

104 F.2d 27 (1939)

SOUTH ALABAMA LAND CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

May 23, 1939.

Attorney(s) appearing for the Case

Geo. E. H. Goodner, of Washington, D. C., for petitioner.

Wm. B. Waldo and Sewall Key, Sp. Assts. to Atty. Gen., Jas. W. Morris, Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Claude R. Marshall, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before SIBLEY, HOLMES, and McCORD, Circuit Judges.

HOLMES, Circuit Judge.

We are called upon to review a decision of the Board of Tax Appeals fixing the 1913 value of 15,500 acres of cut-over land in Escambia County, Alabama, at $5 per acre, as against petitioner's contention that it should be $6 per acre.

The South Alabama Land Company was organized in February, 1912, and, at that time, acquired 20,000 acres of land in said county in exchange for its capital stock. It set the land up on its books at $100...

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