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GARLOCK, INC. v. C. I. R.

No. 60, Docket 72-2108.

489 F.2d 197 (1973)

GARLOCK, INC., Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Second Circuit.

Decided December 12, 1973.

Attorney(s) appearing for the Case

Robert D. Whoriskey, New York City (Curtis, Mallet-Prevost, Colt & Mosle and Winthrop R. Munyan, Lester D. Bailey, and Alfred Grotell, New York City, of counsel), for appellant.

David E. Carmack, Washington, D. C. (Scott P. Crampton, Asst. Atty. Gen., of the United States, Meyer Rothwacks, and Elmer J. Kelsey, Washington, D. C., on the brief), for appellee.

Before SMITH, MANSFIELD and OAKES, Circuit Judges.

OAKES, Circuit Judge:

This is an appeal from a decision of the Tax Court, 58 T.C. 423 (1972) determining deficiencies in income tax from the appellant, Garlock, Inc. (Garlock), for its fiscal year ending December 27, 1964, in the sum of $93,335.83, and that ending December 26, 1965, in the sum of $27,061.49. These determinations were made on the basis that Garlock, S.A. (S.A.), a Panamanian...

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