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ALLSTATE SAV. & LOAN ASS'N v. C. I. R.

No. 77-3221.

600 F.2d 760 (1979)

ALLSTATE SAVINGS & LOAN ASSOCIATION, Successor-in-Interest to Metropolitan Savings and Loan Association of Los Angeles, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

July 13, 1979.

Attorney(s) appearing for the Case

Robert J. Wynne (argued), Hill, Wynne, Troop & Meisinger, Los Angeles, Cal., on brief, for petitioner-appellant.

M. Carr Ferguson, Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D. C., on brief, for respondent-appellee; Richard Farber, Tax Div., Dept. of Justice, Washington, D. C., argued.

Before TRASK, GOODWIN and SNEED, Circuit Judges.

SNEED, Circuit Judge:

Appellant-taxpayer, Allstate Savings and Loan Association, appeals to set aside a Tax Court judgment for the Commissioner. Appellant had sought a redetermination of alleged tax deficiencies for the years 1968 and 1969. On December 17, 1973, the Commissioner determined that appellant's predecessor-in-interest, Metropolitan Savings & Loan Association, had erroneously deducted under section 162(a) of the Internal Revenue Code, certain selling...

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