GALLATIN FARMERS CO. v. COMMISSIONER OF INTERNAL REV.

No. 10164.

132 F.2d 706 (1942)

GALLATIN FARMERS CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

December 31, 1942.


Attorney(s) appearing for the Case

J. M. Stotesbury and Norma E. Skarsten, both of San Francisco, Cal., for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, A. F. Prescott, and Mamie S. Price, Sp. Assts. to Atty. Gen., for respondent.

Before WILBUR, DENMAN and HEALY, Circuit Judges.


DENMAN, Circuit Judge.

Petitioner, a farmers' cooperative corporation created under Chapter 38 of the Revised Codes of Montana, seeks a review of a decision and order of the Tax Court of the United States disallowing deductions (a) from petitioner's income for the calendar tax years 1938 and 1939 of moneys paid to its preferred stockholders, which petitioner claimed to be deductible as interest, and (b) from its income for the calendar year 1939 of moneys paid, as...

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