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WOOLFORD REALTY CO. v. ROSE

No. 582.

286 U.S. 319 (1932)

WOOLFORD REALTY CO., INC. v. ROSE, COLLECTOR OF INTERNAL REVENUE.

Supreme Court of United States.

Decided May 16, 1932.

Attorney(s) appearing for the Case

Mr. Wm. A. Sutherland, with whom Mr. Joseph B. Brennan was on the brief, for petitioner.

Mr. Whitney North Seymour, with whom Solicitor General Thacher, Assistant Attorney General Youngquist, and Messrs. Sewall Key, John H. McEvers, and Wilbur H. Friedman were on the brief, for respondent.

MR. JUSTICE CARDOZO delivered the opinion of the Court.

Petitioner and Piedmont Savings Company are separate corporations organized in Georgia. They became affiliated in 1927 when the petitioner became the owner of 96% of the Piedmont stock. In March, 1928, the two corporations filed a consolidated income tax return for 1927 under § 240 of the Revenue Act of 1926. Revenue Act...

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