Commissioner of Internal Revenue v. RAINIER BREWING COMPANY

Ninth Circuit

Commissioner of Internal Revenue v. RAINIER BREWING COMPANY

165 F.2d 217, 76 U.S.P.Q. (BNA) 565, 36 A.F.T.R. (P-H) 519, 1948 U.S. App. LEXIS 1913

CourtCourt of Appeals for the Ninth Circuit

DecidedJanuary 8, 1948

Docket11547

StatusPublished

Cited by4 cases

This text of 165 F.2d 217 (Commissioner of Internal Revenue v. RAINIER BREWING COMPANY) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Commissioner of Internal Revenue v. RAINIER BREWING COMPANY, 165 F.2d 217, 76 U.S.P.Q. (BNA) 565, 36 A.F.T.R. (P-H) 519, 1948 U.S. App. LEXIS 1913 (9th Cir. 1948).

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Opinion

PER CURIAM.

This, as the companion case of Seattle Brewing and Malting Co., 9 Cir., 165 F.2d 216, presented to the Tax Court “hybrid questions of mixed law and fact [and] their resolution because of the fact element will * * * afford little concrete guidance to future cases.” We hence do not consider the petitioner’s contention that “the facts found fall short of meeting statutory requirements.” Bingham v. Commissioner, 325 U.S. 365, 370, 65 S.Ct. 1232, 89 L.Ed. 1670; Choate v. Commissioner, 324 U.S. 1, 65 S.Ct. 469, 89 L.Ed. 653.

The decision of the Tax Court is affirmed.

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PER CURIAM.

This, as the companion case of Seattle Brewing and Malting Co., 9 Cir., 165 F.2d 216, presented to the Tax Court “hybrid questions of mixed law and fact [and] their resolution because of the fact element will * * * afford little concrete guidance to future cases.” We hence do not consider the petitioner’s contention that “the facts found fall short of meeting statutory requirements.” Bingham v. Commissioner, 325 U.S. 365, 370, 65 S.Ct. 1232, 89 L.Ed. 1670; Choate v. Commissioner, 324 U.S. 1, 65 S.Ct. 469, 89 L.Ed. 653.

The decision of the Tax Court is affirmed.

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165 F.2d 217, 76 U.S.P.Q. (BNA) 565, 36 A.F.T.R. (P-H) 519, 1948 U.S. App. LEXIS 1913, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commissioner-of-internal-revenue-v-rainier-brewing-company-ca9-1948.

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