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RUUD MFG. CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 4290.

45 F.2d 63 (1930)

RUUD MFG. CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

November 8, 1930.

Attorney(s) appearing for the Case

Maynard Teall and Smith, Shaw, McClay & Seifert, all of Pittsburgh, Pa., for petitioner.

G. A. Youngquist, Asst. Atty. Gen., and Norman D. Keller and J. Louis Monarch, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and E. Riley Campbell, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before BUFFINGTON and DAVIS, Circuit Judges, and JOHNSON, District Judge.

DAVIS, Circuit Judge.

This case is here on petition of the taxpayer to review the decision of the Board of Tax Appeals involving taxes for the years 1920 and 1921.

The petitioner is a New Jersey corporation, which during the taxable years in question had its principal office in Pittsburgh, Pa., and was engaged in the manufacture and sale of gas water heaters.

Prior to 1913, the Humphrey Company, a Michigan corporation...

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