
    Seaboard Small Loan Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent.
    Docket No. 98375.
    Promulgated September 24, 1940.
    
      Norman B. Frost, Esq., for the petitioner.
    
      Philip A. Bayer, Esq., for the respondent.
    
      
       Originally entered as a memorandum opinion of same date.
    
   OPINION.

Keen:

The questions raised in this proceeding were recently considered by the Circuit Court of Appeals for the First Circuit in the case of Noteman v. Welch, 108 Fed. (2d) 206 (December 22, 1939), affirming 24 Fed. Supp. 437, and decided contrary to the contentions of tbe petitioner.

On tbe authority of that case and because of tbe reasons therein given,

Decision will he entered for respondent.  