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UNITED STATES v. SWIFT & CO.

No. 56.

282 U.S. 468 (1931)

UNITED STATES v. SWIFT & COMPANY.

Supreme Court of United States.

Decided February 2, 1931.

Attorney(s) appearing for the Case

Assistant Attorney General Rugg, with whom Solicitor General Thacher, and Messrs. Claude R. Branch, Special Assistant to the Attorney General, Charles R. Pollard, Bradley B. Gilman, and Clarence M. Charest, General Counsel Bureau of Internal Revenue, and Ralph E. Smith were on the brief, for the United States.

Mr. G. Carroll Todd, with whom Messrs. Francis E. Baldwin and T. Hardy Todd were on the brief, for respondent.

MR. JUSTICE ROBERTS delivered the opinion of the Court.

This was an action by respondent for the recovery of the amount of an admitted overpayment of income and war-profits taxes for the taxable year 1917, with interest.

In its return for 1917 respondent included the value of stock dividends received. February 28, 1923, it filed a claim for refund, alleging that the dividends in question should have been allocated...

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