Opinion · Court of Appeals for the Ninth Circuit
Seattle Brewing & Malting Company v. COMMISSIONER OF INTERNAL REVENUE
Seattle Brewing & Malting Co. v. Comm’r OF INTERNAL REVENUE, 165 F.2d 216 (9th Cir. 1948)
- Type
- Opinion
- Court
- Court of Appeals for the Ninth Circuit
- Jurisdiction
- Federal
- Date
- 1948-01-08
- Topic
- general
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.
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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.