FIRST NAT. CORP. v. COMMISSIONER OF INTERNAL REVENUE

No. 10704.

147 F.2d 462 (1945)

FIRST NAT. CORPORATION OF PORTLAND v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

January 23, 1945.


Attorney(s) appearing for the Case

George H. Koster and Bayley Kohlmeier, both of San Francisco, Cal., for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, A. F. Prescott, Harold C. Wilkenfeld, and Helen Goodner, Sp. Assts. to the Atty. Gen., for respondent.

Before DENMAN, HEALY, and BONE, Circuit Judges.


HEALY, Circuit Judge.

This is a petition to review a decision of the Tax Court sustaining the assessment of deficiencies in income and excess profits taxes of the petitioning taxpayer for the year 1937.

Taxpayer's books were kept on the accrual basis. At all times here material more than 95% of its voting stock was owned by Transamerica Corporation. The taxpayer owned all the stock of four small Oregon banks. The taxpayer and Transamerica between them owned...

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