Harriman National Bank v. Com'r of Internal Revenue

SWAN, Circuit Judge.

The opinion below, reported in 14 B. T. A. 743, states that the sole question presented to the Board-was whether the bank was a dealer in securities during the taxable years under review, and as sueh entitled to return its income on the basis of inventories of its securities. The Commissioner had denied it the use of inventories, resulting in the imposition of deficiencies in taxes aggregating some $220,000. The Board of Tax Appeals confirmed these deficiencies on the ground that the evidence was insufficient and left the Board in doubt whether or not the bank was a dealer…