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BAY COUNTIES TITLE GUARANTY CO. v. C. I. R.

No. 17050.

288 F.2d 187 (1961)

BAY COUNTIES TITLE GUARANTY CO. (formerly Bay Counties Escrow Co.), Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

March 14, 1961.

Attorney(s) appearing for the Case

Joseph S. Rogers, Peart, Baraty & Hassard, Kenneth S. Carey, San Francisco, Cal., for appellant.

Abbott M. Sellers, Acting Asst. Atty. Gen., Lee A. Jackson, A. F. Prescott, L. W. Post, Meyer Rothwacks, Gilbert E. Andrews, Jr., attorneys, Dept. of Justice, Washington, D. C., for appellee.

Before ORR, HAMLIN and MERRILL, Circuit Judges.

PER CURIAM.

Bay Counties Title Guaranty Co. has petitioned this court to review a decision of the Tax Court determining deficiencies in payments by petitioner for income taxes in the sum of $2,068.80 for 1952, $2,574.30 for 1953, and $1,924.71 for 1954.

Petitioner is an underwriter title company engaged in business in San Francisco. During these years it expended certain sums for title reports prepared by other companies, known as "starters," which upon purchase...

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