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PELICAN ICE CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 5554.

37 F.2d 285 (1930)

PELICAN ICE CO., Limited, et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

January 15, 1930.

Attorney(s) appearing for the Case

Edwin T. Merrick, Ralph J. Schwarz, and Morris B. Redmann, all of New Orleans, La., for petitioners.

C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Percy S. Crewe, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., Sewall Key, and Helen R. Carloss, Sp. Assts. to the Atty. Gen., and Mabel Walker Willebrandt, Asst. Atty. Gen. (G. A. Youngquist, Asst. Atty. Gen., on the brief), for respondent.

Before WALKER, BRYAN, and FOSTER, Circuit Judges.

BRYAN, Circuit Judge.

This is a petition for review of a decision of the United States Board of Tax Appeals upon proceedings for redetermination of deficiencies in taxes on income and excess profits for the years 1920 and 1921 of the Pelican Ice Company and the Pelican Cold-Storage & Warehouse Company. That decision, which is reported in 11 B. T. A. 75, held that the two corporations were not affiliated within the meaning of the Revenue Acts of 1918 and 1921,...

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