MARTIN GENERAL AGENCY v. COMMISSIONER OF INTERNAL REV.

No. 8747.

101 F.2d 165 (1939)

MARTIN GENERAL AGENCY v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

January 24, 1939.


Attorney(s) appearing for the Case

H. C. Belt, of Seattle, Wash., for petitioner.

James W. Morris, Asst. Atty. Gen., and Sewall Key, Norman D. Keller, Berryman Green, and Oliver W. Hammonds, Sp. Assts. to Atty. Gen., for respondent.

Before GARRECHT, HANEY, and STEPHENS, Circuit Judges.


STEPHENS, Circuit Judge.

Review is sought of a decision of the Board of Tax Appeals which sustained a determination of respondent that there was a deficiency of $3,358.02 in income tax and a deficiency of $127.35 in excess profits tax paid by petitioner for the year 1934.

The question to be decided is whether, under §§ 23 and 117 of the Revenue Act of 1934, 48 Stat. 680, 688, 714, 26 U.S.C.A. §§ 23, 101, upon the liquidation of a corporation...

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