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H. H. ROBERTSON CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 9637.

176 F.2d 704 (1949)

H. H. ROBERTSON CO. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Third Circuit.

Decided August 31, 1949.

Attorney(s) appearing for the Case

Sidney B. Gambill, Pittsburgh, Pa. (W. A. Seifert, William Wallace Booth, Norman D. Keller, Pittsburgh, Pa., Reed, Smith, Shaw & McClay Pittsburgh, Pa., on the brief) for petitioner.

Carlton Fox, Washington, D. C. (Theron Lamar Caudle, Assistant Attorney General, Ellis N. Slack, Special Assistant to the Attorney General, on the brief) for respondent.

Before McLAUGHLIN, O'CONNELL and KALODNER, Circuit Judges.

O'CONNELL, Circuit Judge.

Taxpayer ("Robertson") is a Pennsylvania corporation, on an accrual tax basis, which has manufactured and sold building material products in both the United States and Great Britain. The instant controversy centers around the proper interpretation and application of sections 131 and 729 of the Internal Revenue Code, 26 U.S. C.A. §§ 131, 729, to the federal tax liability of Robertson for the year 1940.1

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