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C. I. R. v. SEABOARD FINANCE COMPANY

Nos. 20159-20174.

367 F.2d 646 (1966)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. SEABOARD FINANCE COMPANY et al., Respondents. SEABOARD FINANCE COMPANY et al., Cross Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Cross Respondent.

United States Court of Appeals Ninth Circuit.

October 5, 1966.

Attorney(s) appearing for the Case

Richard M. Roberts, Acting Asst. Atty. Gen., Meyer Rothwacks, David O. Walter, Ralph A. Mupip, Lee A. Jackson, Fred R. Becker, Attys., Dept. of Justice, Washington, D. C., for petitioner.

Austin H. Peck, Jr., H. Hal Visick, Latham & Watkins, Los Angeles, Cal., for respondents.

Before JOHNSEN, BARNES and HAMLEY, Circuit Judges.

HAMLEY, Circuit Judge:

The Commissioner of Internal Revenue filed these consolidated petitions for review of decisions of the Tax Court involving federal income taxes for fiscal years ending in 1955, 1956, 1957 and 1958. The taxpayers, Seaboard Finance Company and fourteen of its subsidiaries (Seaboard), all engaged in the small loan business, filed cross petitions.

The Tax Court had the problem of determining how much, if any, of the amount paid by Seaboard...

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