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HOME TRUST CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 9420.

65 F.2d 532 (1933)

HOME TRUST CO. et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

May 11, 1933.

Attorney(s) appearing for the Case

Phil D. Morelock, of Kansas City, Mo. (Butler Disman, Perry W. Shrader, and Shouse, Doolittle, Morelock & Shrader, all of Kansas City, Mo., on the brief), for petitioners.

Helen R. Carloss, Sp. Asst. to Atty. Gen. (G. A. Youngquist, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and A. H. Fast, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for respondent.

Before STONE and KENYON, Circuit Judges, and REEVES, District Judge.

KENYON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals entered May 29, 1931. The Home Trust Company and the Home Safe Deposit Company, petitioners, are affiliated companies, and filed consolidated returns for 1923 and 1924. The matter was dealt with by the Board as if only one petitioner were involved, and we shall follow for convenience that procedure. Only one question is in dispute, to wit: Whether $75,000 paid by the Home...

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