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JACKSON FINANCE & THRIFT CO. v. COMMISSIONER OF INT. REV.

Nos. 5893, 5894.

260 F.2d 578 (1958)

JACKSON FINANCE and THRIFT CO., a Utah corporation, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. FORD FINANCE COMPANY, a Utah corporation, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Tenth Circuit.

October 21, 1958.

Attorney(s) appearing for the Case

Sanford M. Stoddard, Salt Lake City, Utah (K. Jay Holdsworth, Salt Lake City, Utah, was with him on the brief), for petitioners.

Marvin W. Weinstein, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Grant W. Wiprud and Kenneth E. Levin, Attys., Dept. of Justice, Washington, D. C., were with him on the brief), for respondent.

Before BRATTON, Chief Judge, and PHILLIPS and LEWIS, Circuit Judges.

LEWIS, Circuit Judge.

These appeals from a decision of the Tax Court were consolidated, as were the proceedings below, because of the existence of a controlling law question. No. 5893 involves tax deficiencies imposed upon Jackson Finance and Thrift Co. for the fiscal years ended April 30, 1951, 1952 and 1953; the companion case imposes similar deficiencies upon Ford Finance Co. for the calendar years 1951, 1952 and 1953.

The controversies arose under the...

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