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BEAUCHAMP & BROWN GROVES CO. v. C. I. R.

No. 20423.

371 F.2d 942 (1967)

BEAUCHAMP & BROWN GROVES CO., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

January 19, 1967.

Attorney(s) appearing for the Case

F. Edward Little, Los Angeles, Cal., for appellant.

Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Edward Lee Rogers, Attys., Tax Div., Dept. of Justice, Washington, D.C., for appellee.

Before BARNES and ELY, Circuit Judges, and PECKHAM, District Judge.

BARNES, Circuit Judge:

This is a taxpayer's petition to review a decision of the Tax Court of the United States. (44 T.C. 117.) The Tax Court had jurisdiction under 26 U.S.C. § 7442. Our jurisdiction rests on 26 U.S.C. § 7482.

Petitioner is a dissolved corporation which formerly operated an orange grove. For its fiscal years 1958 and 1959 it had taxable income and paid the proper amounts of tax thereon.

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