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RAYMOND I. SMITH, INC. v. C. I. R.

No. 17015.

292 F.2d 470 (1961)

RAYMOND I. SMITH, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

Rehearing Denied August 7, 1961.

Attorney(s) appearing for the Case

Valentine Brookes, Paul E. Anderson, Richard A. Wilson, San Francisco, Cal., for petitioner.

Abbott M. Sellers, Acting Asst. Atty. Gen., Lee A. Jackson, Melva M. Graney, Michael I. Smith and Kenneth Levin, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before POPE, HAMLEY and KOELSCH, Circuit Judges.

HAMLEY, Circuit Judge.

The Commissioner of Internal Revenue gave Raymond I. Smith, Inc., notice of his determination that there were deficiencies in the taxpayer's income and excess profits taxes for the years 1950, 1952, 1953 and 1954. The company petioned the Tax Court for a redetermination of the deficiencies. Prior to trial the parties settled by stipulation all claimed deficiencies except those for accumulated earnings taxes asserted under section 102(a) of the...

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