Commissioner of Internal Revenue v. East Coast Oil Co.

FOSTER, Circuit Judge.

This is a petition by the Commissioner of Internal Revenue to reverse a decision of the Board of Tax Appeals. It appears that the commissioner assessed income and profits taxes against East Coast Oil Company, S. A., hereafter referred to as the company, for the years 1919, 1920, and 1921, totaling some $487,957. On petition of the company to the board the ruling of the commissioner was reversed and the board determined there was no deficiency. The question presented for decision is whether profits derived from sales of crude petroleum by the company was income derived…