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JACKSON IRON & STEEL CO. v. COMMISSIONER OF INT. REVENUE

No. 5781.

54 F.2d 861 (1931)

JACKSON IRON & STEEL CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

December 30, 1931.

Attorney(s) appearing for the Case

R. S. Doyle, of Washington, D. C., and J. S. Graydon, of Cincinnati, Ohio (Charles D. Hamel, Richard S. Doyle, John Enrietto, and Hamel, Doyle, Park & Saunders, all of Washington, D. C., on the brief), for appellant.

F. E. Mitchell, of Washington, D. C. (G. A. Youngquist, Asst. Atty. Gen., and Sewall Key, F. Edward Mitchell, C. M. Charest, and J. K. Polk, all of Washington, D. C., on the brief), for respondent.

Before MOORMAN, HICKS, and HICKENLOOPER, Circuit Judges.

HICKENLOOPER, Circuit Judge.

With its tax return for the year 1918 petitioner filed an application for special relief under sections 327 and 328 of the Revenue Act of 1918, c. 18, 40 Stat. 1057, 1093. While it had estimated its tax at $174,500 in its tentative return filed March 13, 1919, the complete return filed June 14, 1919, showed taxes payable in the sum of $235,646.33 in the event that special relief was not granted; and the application for such relief which...

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