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BURNET v. ALUMINUM GOODS CO.

No. 192.

287 U.S. 544 (1933)

BURNET, COMMISSIONER OF INTERNAL REVENUE, v. ALUMINUM GOODS MANUFACTURING CO.

Supreme Court of United States.

Decided January 9, 1933.

Attorney(s) appearing for the Case

Assistant Attorney General Youngquist, with whom Solicitor General Thacher and Messrs. Whitney North Seymour, Sewall Key, and John MacC. Hudson were on the brief, for petitioner.

Mr. Frederic Sammond, with whom Messrs. Edwin S. Mack, Arthur W. Fairchild, J. Gilbert Hardgrove, and Paul F. Meyers were on the brief, for respondent.

Mr. Ward Loveless, by leave of Court, filed a brief as amicus curiae.

MR. JUSTICE STONE delivered the opinion of the Court.

In 1914 respondent, a New Jersey manufacturing corporation, purchased all the capital stock of the Aluminum Sales and Manufacturing Company, a New York corporation. From that time until its liquidation, carried on in 1917, the Sales Company was principally engaged in selling goods manufactured by respondent. In February, 1918, it was dissolved. The operation of the Sales Company reflected net losses during the...

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