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KEEN & WOOLF OIL CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 5806.

49 F.2d 45 (1931)

KEEN & WOOLF OIL CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

April 14, 1931.

Attorney(s) appearing for the Case

Robert A. Littleton, of Washington, D. C., for petitioner.

G. A. Youngquist, Asst. Atty. Gen., Sewall Key, J. Louis Monarch, and Helen R. Carloss, Sp. Assts. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and A. H. Pierce, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before BRYAN, SIBLEY, and HUTCHESON, Circuit Judges.

SIBLEY, Circuit Judge.

Petitioner, Keen & Woolf Oil Company, is a corporation from which an excess profits tax was due for its fiscal year ending May 31, 1920. The sole dispute is over the value to be given to one item of its invested capital, being oil leases for which the company at its organization on May 22, 1919, paid to Keen & Woolf, a partnership, 1,100 shares of its preferred stock at a par value of $110,000, and its entire common stock, 30,000 shares...

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