BATT v. UNITED STATES

No. 11091.

151 F.2d 949 (1945)

BATT v. UNITED STATES.

Circuit Court of Appeals, Ninth Circuit.

November 23, 1945.


Attorney(s) appearing for the Case

Sam S. Griffin and William H. Langroise, both of Boise, Idaho, for appellant.

Samuel O. Clark, Jr., Asst. Atty. Gen., Tax Division, Sewall Key, A. F. Prescott, John W. Fisher, and Leonard Sarner, Sp. Assts. to Atty. Gen., and John A. Carver, U. S. Atty., and Erle H. Casterlin, Asst. U. S. Atty., both of Boise, Idaho, for appellee.

Before GARRECHT, MATHEWS, and HEALY, Circuit Judges.


HEALY, Circuit Judge.

The appeal is from a judgment in favor of the United States in an action brought pursuant to § 3744 Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 3744, for the recovery of taxes for the year 1938, claimed to be payable as unemployment compensation under Title IX of the Social Security Act, 42 U.S.C.A. § 1101 et seq.

We summarize the facts as stipulated below. Appellant was a farmer owning or leasing some 800 acres...

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