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COMMISSIONER OF INT. REV. v. SECURITY-FIRST NAT. BANK

No. 10554.

148 F.2d 937 (1945)

COMMISSIONER OF INTERNAL REVENUE v. SECURITY-FIRST NAT. BANK OF LOS ANGELES et al.

Circuit Court of Appeals, Ninth Circuit.

April 30, 1945.

Attorney(s) appearing for the Case

Samuel O. Clark, Jr., Asst. Atty. Gen., Sewall Key, J. Louis Monarch, Helen Goodner, and Hilbert P. Zarky, Sp. Assts. to Atty. Gen., for petitioner.

A. Calder Mackay, Arthur McGregor, and Howard W. Reynolds, all of Los Angeles, Cal., for respondent.

Before DENMAN, STEPHENS and HEALY, Circuit Judges.

DENMAN, Circuit Judge.

The Commissioner of Internal Revenue seeks review of an order of the Tax Court holding the organization for which the Security-First National Bank of Los Angeles is trustee is not taxable for the tax years 1937, 1938 and 1939 as an association corporate in essence within the meaning of Section 1001(a) (2) of the Revenue Act of 1936, Section 901(a) (2) of the Revenue Act of 1938, and Section 3797(a)...

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