M. C. PARRISH & CO. v. COMMISSIONER OF INTERNAL REV.

No. 11171.

147 F.2d 284 (1945)

M. C. PARRISH & CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

February 14, 1945.


Attorney(s) appearing for the Case

R. B. Cannon, of Fort Worth, Tex., for petitioner.

Harold C. Wilkenfeld, Sewall Key, and Helen R. Carloss, Sp. Assts. to the Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Rollin H. Transue, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before SIBLEY, HOLMES, and WALLER, Circuit Judges.


HOLMES, Circuit Judge.

The Tax Court sustained deficiencies assessed by the Commissioner with respect to petitioner's income and excess profits tax returns for the calendar years 1937, 1939, and 1940. The decisive question upon review is whether profits, realized by petitioner through the purchase of non-interest-bearing treasuring warrants of the State of Texas at a discount and holding them until paid, were exempt from gross income as interest on state obligations...

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