Burbank Liquidating Corporation (Formerly Burbank Savings & Loan Association) v. Commissioner of Internal Revenue, United Associates, Inc., (Formerly United Savings & Loan Association) v. Commissioner of Internal Revenue

335 F.2d 125 64-2 USTC P 9676 BURBANK LIQUIDATING CORPORATION (formerly Burbank Savings & Loan Association), Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. UNITED ASSOCIATES, INC., (formerly United Savings & Loan Association), Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. No. 18972. United States Court of Appeals Ninth Circuit. July 29, 1964. Marion E. Gubler, Rogan and Radding, Burbank, Cal., for petitioners. Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Fred E. Youngman, Dept. of Justice, Washington, D.C., for respondent. 1 Before BARNES and BROWNING, Circuit Judges, and HALL, District Judge. 2 HALL, District Judge. 3 In these consolidated appeals from the Tax Court ( 39 T.C. 999 ) this court has jurisdiction under 26 U.S.C. 7482. 4 The tax here in question is for the fiscal year ending February 28, 1955. The briefs are replete with calculations of dollar formulas which make the questions appear complicated, but the question, common to both appellants, is a simple one. It is not the precise number of dollars which may or may not be owed by the taxpayer but whether or not the formula prescribed by Section 593 of the…