SWAN, Circuit Judge.
Handy & Harman is a New York corporation. Hamilton & De Loss, Inc., is a Connecticut corporation. The issue presented by this appeal is whether from January 1, 1918, to February 1, 1919, they were affiliated corporations within the meaning of section 240 (b) of the Revenue Act of 1918 (40 Stat. 1057, 1082). The Commissioner ruled against affiliation, and denied the use of consolidated returns in determining the petitioner's
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