Court of Appeals for the Ninth Circuit March 21, 1932, 6579 (Angelus Building & Investment Co. v. Com'r of Int. Rev.)

JAMES, District Judge.

In this proceeding, brought by the petitioner corporation, to review a decision of the Board o^ Tax Appeals, there is presented the question whether certain payments, made by the petitioner in 1922 to persons listed as holders of its stock, are to be considered as dividends, or as interest on money borrowed.