U. S. Pumice Company v. Commissioner of Internal Revenue

POOLE, Circuit Judge:

Appellant, U.S. Pumice Co., is an integrated miner-manufacturer of pumice, a porous light weight volcanic rock used as an abrasive or polish. The pumice is mined in Northern California and transported to appellant’s mill where it is cut and shaped into various sizes suitable for commercial use. The finished product is then shipped by common carrier to its warehouses in Los Angeles, Chicago and New York where it is stored until ordered by a customer.

Appellant challenges the Tax Commissioner’s finding of deficiency for the years 1965, 1966, 1967 and 1968. Both parties agree…