Allstate Savings & Loan Association v. Commissioner Of Internal Revenue

600 F.2d 760 79-2 USTC P 9478 ALLSTATE SAVINGS & LOAN ASSOCIATION, Successor-in-Interest to Metropolitan Savings and Loan Association of Los Angeles, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 77-3221. United States Court of Appeals, Ninth Circuit. July 13, 1979. Robert J. Wynne (argued), Hill, Wynne, Troop & Meisinger, Los Angeles, Cal., on brief, for petitioner-appellant. M. Carr Ferguson, Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D. C., on brief, for respondent-appellee; Richard Farber, Tax Div., Dept. of Justice, Washington, D. C., argued. Appeal from a Decision of the United States Tax Court. Before TRASK, GOODWIN and SNEED, Circuit Judges. SNEED, Circuit Judge: 1 Appellant-taxpayer, Allstate Savings and Loan Association, appeals to set aside a Tax Court judgment for the Commissioner. Appellant had sought a redetermination of alleged tax deficiencies for the years 1968 and 1969. On December 17, 1973, the Commissioner determined that appellant's predecessor-in-interest, Metropolitan Savings & Loan Association, had erroneously deducted under section 162(a) of the Internal Revenue Code, certain selling…