Baboquivari Cattle Co. v. Commissioner of Internal Rev.

HEALY, Circuit Judge.

Petition to review a decision of the Board of Tax Appeals sustaining the assessment of deficiencies in income taxes for 1937 and 1938. The case concerns the taxability as income of payments made to the petitioner by the United States in accordance with the Soil Conservation and Domestic Allotment Act.

Petitioner is an Arizona corporation. In the taxable years it was engaged in the operation of a cattle ranch comprising 57,200 acres. Of the ranch area 7,319 acres belonged to petitioner and 45,880 acres to the state of Arizona, the latter being held under grazing leases of…