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COMMISSIONER OF INTERNAL REVENUE v. GODFREY

Nos. 201, 202.

50 F.2d 79 (1931)

COMMISSIONER OF INTERNAL REVENUE v. GODFREY. SAME v. FIRST NAT. BANK OF BRIDGEPORT, CONN.

Circuit Court of Appeals, Second Circuit.

May 18, 1931.

Attorney(s) appearing for the Case

G. A. Youngquist, Asst. Atty. Gen., and Sewall Key and Norman D. Keller, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Stanley Suydam, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for petitioner.

Harvey K. Zollinger, of New York City (Marion W. Ripy, of New York City, of counsel), for respondents.

Before MANTON, L. HAND, and CHASE, Circuit Judges.

MANTON, Circuit Judge.

These cases will be considered in one opinion. In 1918, the Yalelms Corporation's income and profits tax was $95,580, a claim for which is asserted against the respondents, stockholders, officers, and transferees of the property of the corporation. Section 280, Revenue Act of 1926, 44 Stat. 9, 61 (26 USCA § 1069). The question presented on this appeal is whether or not the statute of limitations has barred the assessment of the taxes, or...

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