SOUTHERN PAC. CO. v. EDWARDS


57 F.2d 891 (1932)

SOUTHERN PAC. CO. v. EDWARDS, Collector of Internal Revenue.

District Court, S. D. New York.

April 12, 1932.


Attorney(s) appearing for the Case

Ben C. Dey, of Portland, Or., and George L. Buland and Charles L. Minor, both of New York City, for plaintiff.

George Z. Medalie, U. S. Atty., of New York City (Samuel C. Coleman and Frank Chambers, both of New York City, and Lionel A. Norman, of Washington, D. C., of counsel), for defendant.


FRANK J. COLEMAN, District Judge.

The two questions presented are purely legal and arise in the computation of the plaintiff's excess profits tax for the year 1917. They are (1) what valuation should be allowed for certain land in determining the amount of invested capital, and (2) what effect should be given in a consolidated return to the fact that the land was transferred from one affiliate to another.

The plaintiff had two subsidiary corporations, Southern...

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