U.S. Court of Appeals for the Ninth Circuit, 1948

Seattle Brewing & Malting Company v. COMMISSIONER OF INTERNAL REVENUE

U.S. Court of Appeals for the Ninth Circuit · Decided January 8, 1948 · Denham, Healy, Bone

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 (Federal Reporter, Second Series)

Counsel

Jones & Bronson, H. B. Jones, A. R. Kehoe, R. B. Hooper, Chadwick, Chadwick & Mills, and Stephen F. Chadwick, all of Seattle, Wash., for petitioner., Theron L. Caudle, Asst. Atty. Gen., and Sewall Key, Lee A. Jackson, Melva M. Graney, and I. Henry Kutz, Sp. Assts. to Atty. Gen., for respondent.

Cases that cite this one

1 later published case cites this decision.

Commissioner of Internal Revenue v. RAINIER BREWING COMPANY (9th Cir. 1948)

This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.

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.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.