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PHILADELPHIA RAPID TRANSIT CO. v. UNITED STATES

No. 15962.

8 F.Supp. 152 (1934)

PHILADELPHIA RAPID TRANSIT CO. v. UNITED STATES.

District Court, E. D. Pennsylvania.

September 5, 1934.

Attorney(s) appearing for the Case

Dudley T. Easby, Jr., William R. Spofford, Frederic L. Ballard, and Ballard, Spahr, Andrews & Ingersoll, all of Philadelphia, Pa., for plaintiff.

Thomas J. Curtin, Asst. U. S. Atty., of Philadelphia, Pa., Andrew D. Sharpe, Sp. Asst. to Atty. Gen., Frank J. Wideman, Asst. Atty. Gen., and Charles D. McAvoy, U. S. Atty., of Philadelphia, Pa., for the United States.

KIRKPATRICK, District Judge.

The petitioner, Philadelphia Rapid Transit Company, filed with the Commissioner of Internal Revenue claims for refund of the entire amount of income and profits taxes paid by it for the calendar years 1917, 1922, and 1923, amounting in all to $591,906.62, and upon rejection of the claims brought this action to recover the taxes paid.

The petitioner contends that its income for the years in question was wholly exempt from taxation...

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