CONRAD & CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 2523.

50 F.2d 576 (1931)

CONRAD & CO., Inc., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, First Circuit.

May 28, 1931.


Attorney(s) appearing for the Case

Hugh Satterlee, of New York City (I. Herman Sher, of New York City, Albert S. Lisenby, of Washington, D. C., and Weill, Wolff & Satterlee, of New York City, on the brief), for petitioner.

J. Louis Monarch, Sp. Asst. to Atty. Gen. (G. A. Youngquist, Asst. Atty. Gen., Sewall Key and Helen R. Carloss, Sp. Assts. to Attorney General, and C. M. Charest, Gen. Counsel, and Allin H. Pierce, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for the Commissioner.

Argued before BINGHAM, ANDERSON, and WILSON, Circuit Judges.


WILSON, Circuit Judge.

This is a petition for review of certain orders and decisions of the Board of Tax Appeals holding that the petitioner was subject to certain deficiency taxes for the years 1919, 1920, 1921, and 1922.

The Board of Tax Appeals found as facts that prior to November 1, 1917, Sidney S. Conrad and Bertram B. Conrad conducted a business as partners under the name of Conrad & Co., and on the above date they organized a corporation and transferred...

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