CHASE, Circuit Judge.
During the taxable period involved, the petitioner was one of fourteen corporations whose voting capital stock was all owned by a common parent, the United States Realty & Improvement Company. A consolidated return was filed by the parent for 1932 for itself and all of these affiliated corporations but one. That one was the Savoy-Plaza Corporation, which was in bankruptcy and whose trustee refused to join in the consolidated return but filed...
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