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SEATTLE BREWING & MALTING CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 11467.

166 F.2d 326 (1948)

SEATTLE BREWING & MALTING CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

February 18, 1948.

Attorney(s) appearing for the Case

Jones & Bronson, H. B. Jones, A. R. Kehoe, R. B. Hooper, Chadwick, Chadwick & Mills, and Stephen F. Chadwick, all of Seattle, Wash., for petitioner.

Theron L. Caudle, Asst. Atty. Gen., and Sewall Key, Lee A. Jackson, Melva M. Graney, and I. Henry Kutz, Sp. Assts. to Atty. Gen., for respondent.

Before DENMAN, HEALY and BONE, Circuit Judges.

PER CURIAM.

Petitioner urges that the Tax Court did no more than construe the terms of an undisputed contract for the licensing of the use of the name "Rainier" in its brewing business in the State of Washington. We do not agree. The findings and opinion disclose that the facts adduced at the hearing and by stipulation of the character of the business prior to and during the existence of the contract and of the objectives of the respective boards of directors of the...

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