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BURNET v. CHICAGO PORTRAIT CO.

No. 378.

285 U.S. 1 (1932)

BURNET, COMMISSIONER OF INTERNAL REVENUE, v. CHICAGO PORTRAIT CO.

Supreme Court of United States.

Decided February 23, 1932.

Attorney(s) appearing for the Case

Assistant Attorney General Youngquist, with whom Solicitor General Thacher, and Messrs. Whitney North Seymour, Sewall Key, and Andrew D. Sharpe were on the brief, for petitioner.

Mr. Arnold R. Baar, with whom Mr. Albert L. Hopkins was on the brief, for respondent.

MR. CHIEF JUSTICE HUGHES delivered the opinion of the Court.

This proceeding was brought for the redetermination of a deficiency in income tax for the year 1923. The respondent, Chicago Portrait Company, is an Illinois corporation with its principal place of business at Chicago. It owned 51 per cent. of the capital stock of the International Art Company of Sydney, Australia, a foreign corporation. Respondent received dividends...

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