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HELVERING v. RUSSIAN FINANCE & CONSTRUCTION CORPORATION

Nos. 325, 326.

77 F.2d 324 (1935)

HELVERING, Commissioner of Internal Revenue, v. RUSSIAN FINANCE & CONSTRUCTION CORPORATION. SAME v. GEORGIAN MANGANESE CO., Limited.

Circuit Court of Appeals, Second Circuit.

May 6, 1935.

Attorney(s) appearing for the Case

Frank J. Wideman, Asst. Atty. Gen., and Sewall Key and J. P. Jackson, Sp. Assts. to Atty. Gen., for petitioner.

Davis, Polk, Wardwell, Gardiner & Reed, of New York City (Marion N. Fisher and Marvin Lyons, both of New York City, of counsel), for respondents.

Before MANTON, L. HAND, and AUGUSTUS N. HAND, Circuit Judges.

MANTON, Circuit Judge.

These causes were consolidated for hearing before the Board of Tax Appeals, and are here on petitions to review. The issues involve income taxes for the years 1925, 1926, and 1927. The question is whether the Georgian Manganese Company, Ltd., was entitled to certain deductions from gross income for the years in question. The question affects the tax liability of both respondents because they were affiliated...

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