Commissioner v. Dependable Packing Co.

KERNER, Circuit Judge.

Both the Commissioner of Internal Revenue (hereinafter called the Commissioner) and the claimant, Dependable Packing Company, a partnership, petition for review of adverse portions to them of a decision of the Tax Court. We shall consider them together. Initially Dependable filed a claim with the Commissioner for refund of taxes paid by it as a processor of hogs under the provisions of the Agricultural Adjustment Act, 7 U.S.C.A. § 601 et seq. This claim was disallowed in full. Pursuant to § 906 (g) of the Revenue Act of 1936, 7 U.S.C.A. § 648(g), Dependable filed a…