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UNION GUARDIAN TRUST CO. v. BURNET

No. 5602.

64 F.2d 712 (1933)

UNION GUARDIAN TRUST CO. v. BURNET, Commissioner of Internal Revenue.

Court of Appeals of the District of Columbia.

Decided April 3, 1933.

Rehearing Denied April 21, 1933.

Attorney(s) appearing for the Case

Frederick L. Pearce and Lyman L. Long, both of Washington, D. C., and Arnold R. Baar and Arthur R. Foss, both of Chicago, Ill., for appellant.

G. A. Youngquist, Sewall Key, J. P. Jackson, John MacC. Hudson, C. M. Charest, and Hartford Allen, all of Washington, D. C., for appellee.

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

GRONER, Associate Justice.

In 1916 the taxpayer and a real estate corporation doing business in Detroit entered into a contract, as the result of which the taxpayer undertook to manage a separate department of the corporation for a term of five years in consideration of a percentage of the profits. The contract provided that it might be, as it was, extended one additional year, and this made it terminate in 1922. The contract provided that the corporation should organize...

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