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

Opinion

PER CURIAM.

This, as the companion case of Commission of Internal Revenue v. Rainier Brew 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.