Pacific Transport Co. v. Commissioner

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Pacific Transport Company and Subsidiaries, Appellee-Cross-Appellant v. Commissioner of Internal Revenue, Appellant-Cross-Appellee. Pacific Atlantic Steamship Company, Appellee-Cross-Appellant v. Commissioner of Internal Revenue, Appellant-Cross-Appellee (Two Cases). States Steamship Company, Etc., Appellee-Cross-Appellant v. Commissioner of Internal Revenue, Appellant-Cross-Appellee (Two Cases). States Steamship Company, Appellee-Cross-Appellant v. Commissioner of Internal Revenue, Appellant-Cross-Appellee. Portland Stevedoring Company, Appellee-Cross-Appellant v. Commissioner of Internal Revenue, Appellant-Cross-Appellee (Two Cases). Pacific Transport Lines, Inc., Appellee-Cross-Appellant v. Commissioner of Internal Revenue, Appellant-Cross-Appellee California Eastern Lines, Inc., Appellee-Cross-Appellant v. Commissioner of Internal Revenue, Appellant-Cross-Appellee (Two Cases). Pacific Transport Company, and Subsidiaries, Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Appellee-Cross-Appellant
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KILKENNY, Circuit Judge

(concurring) ;

It is with great hesitation and considerable reluctance that I join in the foregoing opinion. If logical support could be found in the adjudicated authorities, I would introduce into tax law, under circumstances such as these, a principle of equity which would not permit the revenue gathering branch of our government to take advantage of a taxpayer’s well intentioned reliance on the action of another branch. Unfortunately, I am unable to apply to our facts the principles expressed in United States v. Lazy F. C. Ranch, 481 F.2d 985 (C.A.9, 1973).