Seattle Brewing & Malting Company v. COMMISSIONER OF INTERNAL REVENUE

Ninth Circuit

Seattle Brewing & Malting Company v. COMMISSIONER OF INTERNAL REVENUE

165 F.2d 216, 76 U.S.P.Q. (BNA) 565, 36 A.F.T.R. (P-H) 765, 1948 U.S. App. LEXIS 4011

CourtCourt of Appeals for the Ninth Circuit

DecidedJanuary 8, 1948

Docket11467

StatusPublished

Cited by1 cases

This text of 165 F.2d 216 (Seattle Brewing & Malting Company v. COMMISSIONER OF INTERNAL REVENUE) 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.

Bluebook

Seattle Brewing & Malting Company v. COMMISSIONER OF INTERNAL REVENUE, 165 F.2d 216, 76 U.S.P.Q. (BNA) 565, 36 A.F.T.R. (P-H) 765, 1948 U.S. App. LEXIS 4011 (9th Cir. 1948).

Pincite

Opinion

PER CURIAM.

This, as the companion case of Commission of Internal Revenue v. Rainier Brew *217 ing Co., 9 Cir., 165 F.2d 217, presented to the Tax Court “hybrid questions of mixed law and fact [and] their resolution because of the fact element involved 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, 6 T.C. 856, is affirmed.

Free access — add to your briefcase to read the full text and ask questions with AI

PER CURIAM.

This, as the companion case of Commission of Internal Revenue v. Rainier Brew *217 ing Co., 9 Cir., 165 F.2d 217, presented to the Tax Court “hybrid questions of mixed law and fact [and] their resolution because of the fact element involved 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, 6 T.C. 856, is affirmed.

Cite This Page — Counsel Stack

Bluebook (online)

165 F.2d 216, 76 U.S.P.Q. (BNA) 565, 36 A.F.T.R. (P-H) 765, 1948 U.S. App. LEXIS 4011, Counsel Stack Legal Research, https://law.counselstack.com/opinion/seattle-brewing-malting-company-v-commissioner-of-internal-revenue-ca9-1948.

Opinion

Related

Cite This Page — Counsel Stack