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PIONEER POLE & SHAFT CO. v. COMMISSIONER OF INT. REVENUE

No. 5616.

55 F.2d 861 (1932)

PIONEER POLE & SHAFT CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

February 5, 1932.

Attorney(s) appearing for the Case

John Enrietto, of Washington, D. C. (William H. Thompson, Charles D. Hamel, and Hamel, Park & Saunders, all of Washington, D. C., on the brief), for petitioner.

Wm. Cutler Thompson, of Washington, D. C. (G. A. Youngquist, Asst. Atty. Gen., and John H. McEvers, C. M. Charest, and Stanley B. Pierson, all of Washington, D. C., on the brief), for respondent.

Before MOORMAN, HICKS, and HICKENLOOPER, Circuit Judges.

HICKENLOOPER, Circuit Judge.

The Pioneer Pole & Shaft Company was organized as a New Jersey Corporation late in 1902, to combine or consolidate fourteen companies then actively engaged in the same or a kindred business as was thereafter carried on by the new corporation. It is conceded that a substantial value representing the good will of the constituent companies was then "paid in" for capital stock. In 1911 it was thought desirable to change the corporate domicile...

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