United States Board of Tax Appeals July 25, 1932, Docket No. 53552. (Sailors Bros. Co. v. Commissioner)

lead-opinion

*702OPINION.

Sea well :

In the petition, three errors were assigned, therein designated as 4 (a), 4 (b) and 4 (c). The first two of them relate to the manner of apportioning the tax liability among the members of the affiliated group, but at the hearing counsel for the petitioner made the following statements:

In some minor particulars, the Commissioner has denied some allegations as