STEPHENS MARINE, INC. v. C. I. R.

No. 24580.

430 F.2d 679 (1970)

STEPHENS MARINE, INC., Successor in interest to Stephens Brothers, Inc., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Rehearing Denied September 16, 1970.


Attorney(s) appearing for the Case

Robert E. Tout (argued), Stockton, Cal., for petitioner-appellant.

Ann E. Belanger (argued), Lee A. Jackson, Grant W. Wiprud, Attys., Johnnie M. Walters, Ass't Atty. Gen., Tax Div., Dept. of Justice, K. Martin Worthy, Chief Counsel, I.R.S., Washington, D. C., for respondent-appellee.

Before HAMLEY and DUNIWAY, Circuit Judges, and WILLIAMS, District Judge.


DUNIWAY, Circuit Judge:

The taxpayer, Stephens Marine, Inc. [Stephens Marine], successor in interest to Stephens Brothers, Inc. [Stephens Brothers] petitions for review of a Tax Court decision in favor of the Commissioner. T.C. Memo. 1969-39. We affirm. The facts are set out at length by the Tax Court. The following summary will suffice here.

The taxpayer attacks certain deficiencies...

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