PLANET LINE v. COMMISSIONER OF INTERNAL REVENUE

No. 203.

89 F.2d 16 (1937)

PLANET LINE, Inc., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

April 5, 1937.


Attorney(s) appearing for the Case

Frank V. Barns, of New York City, for Planet Line, Inc.

James W. Morris, Asst. Atty. Gen., and Sewall Key and Robert N. Anderson, Sp. Assts. to Atty. Gen., for respondent.

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


CHASE, Circuit Judge.

The petitioner was incorporated in 1923 and entered into an operating agreement with Planet Steamship Corporation covering seven cargo vessels owned by the latter. Petitioner's due and timely performance of the agreement was guaranteed by Seas Shipping Company, Inc., which owned all the outstanding capital stock of the petitioner.

The contract was duly performed by petitioner, that being the only business it conducted, until it was canceled...

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