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WILKINS PONTIAC v. C. I. R.

No. 17299.

298 F.2d 893 (1961)

WILKINS PONTIAC, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. WILKINS PONTIAC, Respondent.

United States Court of Appeals Ninth Circuit.

December 26, 1961.

Attorney(s) appearing for the Case

F. Edward Little and Little, Curry & Hagen, Los Angeles, for petitioner.

John B. Jones, Jr., Acting Asst. Atty. Gen., Meyer Rothwacks and Carolyn R. Just, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before BARNES, MERRILL and BROWNING, Circuit Judges.

MERRILL, Circuit Judge.

Wilkins Pontiac, engaged in the operation of an automobile dealership in Van Nuys, California, has petitioned this court to review a decision of the Tax Court determining a deficiency in federal income tax for the year 1955.

In the course of its business, petitioner sold automobiles and received conditional sales contracts covering the balance due. Petitioner assigned these contracts to GMAC for the full face value without discount...

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