Opinion
No. 7086.
July 14, 1939.
On Petition for Review from the Board of Tax Appeals.
Ruby R. Vale, of Philadelphia, Pa., for petitioner.
James W. Morris, Asst. Atty. Gen., and Sewall Key and Joseph M. Jones, Sp. Assts. to Atty. Gen., for respondent.
Before MARIS, BIDDLE and BUFFINGTON, Circuit Judges.
This case arises out of the same corporate transactions which were before the Court of Claims in Davis v. United States, 26 F. Supp. 1007. It is indistinguishable in principle from Groman v. Commissioner, 302 U.S. 82, 58 S.Ct. 108, 82 L.Ed. 63, Helvering v. Bashford, 302 U.S. 454, 58 S.Ct. 307, 82 L.Ed. 367, and Hedden v. Commissioner, 3 Cir., 105 F.2d 311. The decision of the Board of Tax Appeals is affirmed upon the authority of those cases.