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OLD COLONY TRUST CO. v. COMMISSIONER OF INTERNAL REV.

No. 2670.

59 F.2d 168 (1932)

OLD COLONY TRUST CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, First Circuit.

May 31, 1932.

Attorney(s) appearing for the Case

Herbert P. Mason (of Chamberlin, Stone & Bosson), of Boston, Mass., for petitioners.

J. Louis Monarch, Sp. Asst. to Atty. Gen. (G. A. Youngquist, Asst. Atty. Gen., Norman D. Keller, Sp. Asst. to Atty. Gen., and C. M. Charest, Gen. Counsel, and C. R. Marshall, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for Commissioner.

Before BINGHAM and WILSON, Circuit Judges, and BREWSTER, District Judge.

WILSON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals, and involves the income taxes of Charles J. Shugrue, now deceased, for the calendar year of 1923.

The decedent was the principal stockholder in the Crown Shade & Screen Company, a Massachusetts corporation engaged in the manufacture and sale of window shades and screens. The capital stock of the corporation outstanding prior to 1923 was only $9,700, divided...

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