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UNDERWRITERS SERVICE v. COMMISSIONER OF INT. REV.

No. 15787.

257 F.2d 336 (1958)

UNDERWRITERS SERVICE, Inc., a corporation, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

July 15, 1958.

Attorney(s) appearing for the Case

Thelen, Marrin, Johnson & Bridges, Chester H. Brandon, George E. Link, San Francisco, Cal., for petitioner.

Charles K. Rice, Asst. Atty. Gen., Helen A. Buckley, David O. Walter, I. Henry Kutz, Lee A. Jackson, Attorneys, Department of Justice, Washington, D. C., for respondent.

Before STEPHENS, Chief Judge, and DENMAN and FEE, Circuit Judges.

DENMAN, Circuit Judge.

Underwriters Service, Inc., hereafter Taxpayer, petitions for a review of a decision of the Tax Court in which the Commissioner's noticed deficiencies for income and excess profits taxes for the years 1950, 1951 and 1952 were upheld. All of the factual issues have been stipulated to and the question before us is purely a question of law, the proper amount of Taxpayer's "excess profits net income" for the year 1946. This is relevant to the tax...

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