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HELVERING v. WARDMAN

No. 5878.

68 F.2d 418 (1933)

HELVERING, Commissioner of Internal Revenue v. WARDMAN.

Court of Appeals of the District of Columbia.

Decided December 11, 1933.

Attorney(s) appearing for the Case

G. A. Youngquist, Asst. Atty. Gen., and Sewall Key, C. M. Charest, Arthur H. Fast, J. P. Jackson, F. L. Van Haaften, all of Washington, D. C., for petitioner.

Meredith M. Daubin and Daniel Thew Wright, both of Washington, D. C., for respondent.

Before MARTIN, Chief Justice, and ROBB, HITZ, and GRONER, Associate Justices.

ROBB, Associate Justice.

Petition for review of a decision of the Board of Tax Appeals holding that respondent taxpayer's business, within the meaning of section 229 of the Revenue Act of 19211 (c. 136, 42 Stat. 227), had been organized as a corporation within four months after the passage of the act (November 23, 1921); and that, the business of the taxpayer not being organized as a corporation until March 23, 1922, the filing of an individual...

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