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BENEFICIAL LOAN SOC. v. COMMISSIONER OF INT. REV.

No. 5093.

65 F.2d 759 (1933)

BENEFICIAL LOAN SOC. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

June 8, 1933.

Attorney(s) appearing for the Case

Jackson R. Collins, of New York City, for petitioner.

Sewall Key and Wm. Cutler Thompson, Sp. Assts. U. S. Attys., both of Washington, D. C. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and W. R. Lansford, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before BUFFINGTON, DAVIS, and THOMPSON, Circuit Judges.

THOMPSON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals. The case is submitted upon an agreed stipulation of facts. The petitioner, a Delaware corporation, was organized in 1913 and was thereafter engaged in the business of making industrial loans. During the years 1923, 1924, and 1925, it conducted its business in various localities through subsidiary companies, some of which were incorporated and others unincorporated. The...

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