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COMMISSIONER OF INTERNAL REVENUE v. CHAMPION

No. 6688.

78 F.2d 513 (1935)

COMMISSIONER OF INTERNAL REVENUE v. CHAMPION.

Circuit Court of Appeals, Sixth Circuit.

June 29, 1935.

Attorney(s) appearing for the Case

Morton K. Rothschild, of Washington, D. C. (Frank J. Wideman and Sewall Key, both of Washington, D. C., on the brief), for petitioner.

Walter S. Gordon, of Cleveland, Ohio, for respondent.

Before MOORMAN, HICKS, and ALLEN, Circuit Judges.

HICKS, Circuit Judge.

Petition by the Commissioner of Internal Revenue to review an order of the Board of Tax Appeals. The Commissioner determined a deficiency in respondent's income taxes of $576.70 for 1928 and of $5,523.70 for 1930. The Board found an overpayment of $5,005.92 for 1928 and a small underpayment of $302.04 for 1930.

The evidentiary facts are undisputed. Summarized, they are as follows: Champion Rivet Company was organized in 1903 for the manufacture...

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