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INTERNATIONAL ED. PUB. CO. v. COMMISSIONER OF INT. REV.

No. 5762.

79 F.2d 343 (1935)

INTERNATIONAL EDUCATIONAL PUB. CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

Rehearing Denied September 17, 1935.

Attorney(s) appearing for the Case

Frederick L. Pearce and George M. Morris, of Washington, D. C. (Morris, Kix Miller & Baar, of Washington, D. C., of counsel), for petitioner.

Frank J. Wideman, Asst. Atty. Gen., and Sewall Key and Joseph M. Jones, Sp. Assts. to Atty. Gen., for respondent.

Before WOOLLEY, DAVIS, and THOMPSON, Circuit Judges.

THOMPSON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals. International Publishing Company, the petitioner, was created in 1908 for the purpose of developing the foreign business of the International Textbook Company, a company engaged in sponsoring correspondence school courses. In 1911, the petitioner exchanged 20,000 shares of its preferred stock and 50,000 shares of its common stock for concessions to use the textbooks of...

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