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COMMISSIONER OF INT. REV. v. COASTWISE TRANSP. CORP.

No. 2866.

71 F.2d 104 (1934)

COMMISSIONER OF INTERNAL REVENUE v. COASTWISE TRANSP. CORPORATION.

Circuit Court of Appeals, First Circuit.

May 18, 1934.

Attorney(s) appearing for the Case

J. Louis Monarch, Sp. Asst. to Atty. Gen. (Sewall Key and J. P. Jackson, Sp. Assts. to Atty. Gen., on the brief), for petitioner for review.

Leonard Wheeler, Jr., of Boston, Mass. (Robert E. Goodwin and Allan H. W. Higgins, both of Boston, Mass., on the brief), for Coastwise Transp. Corporation.

Before BINGHAM, WILSON, and MORTON, Circuit Judges.

BINGHAM, Circuit Judge.

The Coastwise Transportation Corporation acquired a fleet of ships from the American Hawaiian Company in 1922 and gave, as part payment therefor, serial notes of the face value of $608,400 secured by mortgage on the ships. In 1924, the corporation purchased for $75,000 two of these notes having a face value of $152,000, thereby making a gain of $77,100; and in 1925, by negotiations through a syndicate, acquired $456,300 of the notes in exchange...

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