COMMISSIONER OF INTERNAL REVENUE, PETITIONER,
v.
RAINIER BREWING COMPANY, A CORPORATION, RESPONDENT

9th Cir. | 1948-01-08
No. 11547
165 F.2d 217 United States Court of Appeals for the Ninth Circuit (1948) Positive Treatment
Cited by 6 cases

Opinion of the Court
PER CURIAM.

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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