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UNION PETROLEUM S. S. CO. v. EDWARDS

No. 308.

7 F.2d 301 (1925)

UNION PETROLEUM S. S. CO. v. EDWARDS, Collector of Internal Revenue.

Circuit Court of Appeals, Second Circuit.

April 6, 1925.

Attorney(s) appearing for the Case

Kirlin, Woolsey, Campbell, Hickox & Keating, of New York City (Delbert M. Tibbetts, of New York City, of counsel), for plaintiff in error.

Thomas J. Crawford, Asst. U. S. Atty., of New York City, opposed.

Before ROGERS, HOUGH, and HAND, Circuit Judges.

PER CURIAM.

However hard this case may appear to some, we are unable to perceive any legal merit in plaintiff's contentions. If it had been able to take title to the Westwego, this British corporation would have been obliged pro tanto at least to submit to taxation by the United States, and non constat that its condition would have been any better than it is now.

What was done was deliberate, including the maintenance of an American corporation to own the...

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