Petitioner, Bear Gulch Water Company, a California corporation, had a net income of $50,099.61 in 1933 and a net income of $55,605.36 in 1634, but paid no federal income tax in either year, its contention being that its income was exempt from federal taxation. Rejecting this contention, rspondent, the Commissioner of Internal Revenue, determined that petitioner owed a tax of $6,888.70 for 1933 and a tax of $7,645.74 for 1934. Respondent was sustained by the Board of Tax Appeals. 40 B.T.A. 1281. The Boards decision is here for review.
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