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FOUNDERS GENERAL CORP. v. COMMISSIONER OF INTERNAL REVENUE

No. 256.

79 F.2d 6 (1935)

FOUNDERS GENERAL CORPORATION v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

July 15, 1935.

Attorney(s) appearing for the Case

Henry J. Richardson, of Washington, D. C., for petitioner.

Frank J. Wideman, Asst. Atty. Gen., and Sewall Key and Morton K. Rothschild, Sp. Assts. to Atty. Gen., for respondent.

Before L. HAND, SWAN, and CHASE, Circuit Judges.

CHASE, Circuit Judge.

During all the time material to the issues presented, the petitioner was the wholly owned subsidiary of the American Founders Corporation, the successor to American Founders Trust. Both were Maryland corporations. Petitioner was organized primarily as a marketing subsidiary for the securities of its parent, and affiliated and associated corporations.

American Founders Corporation filed a consolidated income tax return for the taxable...

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