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MANHATTAN CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 226.

297 U.S. 129 (1936)

MANHATTAN GENERAL EQUIPMENT CO. v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided February 3, 1936.

Attorney(s) appearing for the Case

Mr. Laurence Graves, with whom Messrs. Emil Weitzner, Samuel H. Kaufman, Brode B. Davis, and Isadore Polier were on the brief, for petitioners.

Assistant Solicitor General Bell, with whom Solicitor General Reed, Assistant Attorney General Wideman, and Messrs. Sewall Key, Joseph M. Jones, and John R. Benney were on the brief, for respondent.

MR. JUSTICE SUTHERLAND delivered the opinion of the Court.

These cases involve identical facts and questions of law, and were disposed of by the court below in one opinion. 76 F.2d 892. The facts, so far as they concern the question here, are taken from the statement of that court.

"The petitioners are affiliates of United Brokerage Company. That corporation filed income tax returns for itself and its affiliates for 1925 and...

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