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PACIFIC FRUIT EXCHANGE v. UNITED STATES

No. 42799.

26 F.Supp. 228 (1939)

PACIFIC FRUIT EXCHANGE v. UNITED STATES.

Court of Claims.

February 6, 1939.

Attorney(s) appearing for the Case

John A. Selby, of Washington, D. C. (Lawrence A. Baker and Henry Ravenal, both of Washington, D. C., and Athearn, Chandler & Farmer, of San Francisco, Cal., on the brief), for plaintiff.

Daniel F. Hickey, of Washington, D. C. (James W. Morris, Asst. Atty. Gen. (Robert N. Anderson, Fred K. Dyar, and J. W. Blalock, all of Washington, D. C., on the brief), for defendant.

Before BOOTH, Chief Justice, and WHALEY, LITTLETON, GREEN, and WILLIAMS, Judges.

BOOTH, Chief Justice.

This tax case is submitted upon an agreed statement of facts. The plaintiff, a California corporation, is engaged in growing, packing, and marketing deciduous fruits and other crops. Its business activities embrace growing crops upon its own account, and entering into mortgage-marketing contracts with other growers. It is this last phase of activities which gave rise to this litigation.

A mortgage-marketing contract is an indenture of...

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