by There is. no have to stand om its own merits, the instant in suit the result wouldbe if the however, would certainty what were ease prosecuted to conclusion. offer of settlement the parent company wes Arma Company La et all times the ownerof the patents under whieh all of tie1% firearms in question wore manufactured and for meny yoors, of nad engaged in the business of the gale end dictrisution .s fivearmas prior to the lneorporetionof BSrownins arma GOmpany the making tn for songeding of the sult, that the transfer that Aras eubieet not were company, oontentioa principie its purposes settlement 1.6, niseble for tex purposes, and parent. company.or by Srowning yarent Browning and recog- fide bona was subsequent sales by the Gompany, es agent for the In tc tax. hac the waking - ¢on- thie e thet eession for settlement purposes, tac texpuyer subsit to tiet rcble 1% should be entitled to a taxable basis gsompa basis the to established for ite eompetiters and comparabie been not ory which4% would have been given had the invent "a refuse the taxpayer such e@ bagis is actually transferred, the manu~ to impose & penalty, for we would ha ontitled to use or feoturers basis prioe jobbers been not inventory Cirtransferred, 68 counsel] views the decision of the Bighth euit Gourt of Appeols in =, Albrecht & con, inc. ¥, Coumissioner, 114 P@d.(2) 202. offer tne settlement, toward concession Ae a further (6), ent of 4 contemplates a compromise even as to tie establishm in ded, perio fabbers orice basis on all eales in the suit to the adé@ed been torminine the amount of the offer, there nes is thet refund the of epount change of socount on due clearly ted above in of besia on after imported scales, heretofore compu the allocable pilus 0, the amount of £10,079.95, the sum of 07,50 paid in 1932, yortion of the deficiency interestof $12,806.90 917,579095, d of which would be due upon such principal refun gin “E z eceruead ~ ee elus the etetute ; % § beaome #ill i sig ee && % % ae he the amount of by etatule. g@liowed e 4 Si ES interes. 4 total She making 03,502.05, or Be tens rae ne 2 i a if, — onal interest, does not allowa additi Airs AR. : £4 ies alanaae od a flet ancunt of (21,002.00. »& Mena (21,062, offer y iy Gt Ae. ci tae ve es Age coursed, fy iy He SM) ore ori er St nse. tei is asking "hus the reel concession for which the taxpayer 91,4930975 of sam is the additional refund of 97900, plus the interest, representing the ineressed alioontionof deficiency €17,579 «955 of d wateh anould be refunded on the principal refun principal. the if ed allow in excess of that whieh would have been n in This concessiois, refund of only $10,079.95 were mace, whether eccorued interest pert, requested beoause of tho doubt on any refund that may be made, fe allowable this from was under the statute was made in At ¢he time the original offer in gompromise period sult ease, the amount of gales sade during the iI% d. lishe after imported Tirearma uscd not been estab thought Re @t that time thet thie was only a minor element