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JOSEPH S. WELLS ASS'N v. HELVERING

No. 6121.

71 F.2d 977 (1934)

JOSEPH S. WELLS ASS'N v. HELVERING, Com'r of Internal Revenue.

Court of Appeals of the District of Columbia.

Decided May 28, 1934.

Attorney(s) appearing for the Case

James S. Y. Ivins and Percy W. Phillips, both of Washington, D. C., for appellant.

Sewall Key, E. Barrett Prettyman, Bernard D. Hathcock, J. L. Monarch, and Louise Foster, all of Washington, D. C., for appellee.

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

VAN ORSDEL, Associate Justice.

Appellant company is seeking to set aside a determination of a deficiency of $177.54 found against it by the respondent, Commissioner of Internal Revenue, in income tax for the year 1928; and in addition thereto to recover an alleged overpayment of tax for that year in the amount of $2,475.27.

Appellant is a Utah corporation, organized by the heirs of one Joseph S. Wells, for the purpose of holding and administering certain securities...

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