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COMMISSIONER OF INTERNAL REV. v. CHICAGO PORTRAIT CO.

No. 4434.

50 F.2d 683 (1931)

COMMISSIONER OF INTERNAL REVENUE v. CHICAGO PORTRAIT CO.

Circuit Court of Appeals, Seventh Circuit.

June 11, 1931.

Attorney(s) appearing for the Case

G. A. Youngquist, Asst. Atty. Gen., Sewall Key and A. H. Conner, Sp. Assts. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Dean P. Kimball, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for petitioner.

Albert L. Hopkins, Arnold R. Baar, and Herman T. Reiling, all of Chicago, Ill., for respondents.

Before ALSCHULER, EVANS, and SPARKS, Circuit Judges.

ALSCHULER, Circuit Judge.

Review is sought of a ruling of the Board of Tax Appeals which sustained respondent's contention that it was entitled to deduct from its federal income tax for the year 1923, the amount of an income tax for that year which it was required to pay upon its business done in New South Wales. 16 B. T. A. 1129.

Respondent company is an Illinois corporation, and in the year in question owned 51 per cent. of the voting stock of a subsidiary...

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