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BALKAN NAT. INS. CO. v. COMMISSIONER OF INTERNAL REV.

No. 24.

101 F.2d 75 (1939)

BALKAN NAT. INS. CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

January 9, 1939.

Attorney(s) appearing for the Case

Allen H. Gardner, of Washington, D. C. (Morris, Kixmiller & Baar, of Washington, D. C., of counsel), for petitioner.

James W. Morris, Asst. Atty. Gen., and J. Louis Monarch and Helen R. Carloss, Sp. Assts. to Atty. Gen., for respondent.

Before L. HAND, SWAN, and CHASE, Circuit Judges.

SWAN, Circuit Judge.

The question presented is whether the statute of limitations on assessment and collection of income and profits taxes for the year 1918, during which the petitioner was operating in the United States under a license issued pursuant to the Trading with the Enemy Act, 50 U.S.C.A. Appendix, § 1 et seq., had expired prior to the mailing of a deficiency notice to the petitioner in 1934. The Board of Tax Appeals sustained the deficiency assessment...

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