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HEDDEN v. COMMISSIONER OF INTERNAL REVENUE

Nos. 6971, 6973, 6974, 6972.

105 F.2d 311 (1939)

HEDDEN v. COMMISSIONER OF INTERNAL REVENUE (three cases). CONNEEN v. SAME.

Circuit Court of Appeals, Third Circuit.

June 20, 1939.

Attorney(s) appearing for the Case

Ernest C. Lum, of Newark, N. J., and William Ristig, of Washington, D. C., for petitioners.

James W. Morris, Asst. Atty. Gen., and Sewall Key and Maurice J. Mahoney, Sp. Assts. to Atty. Gen., for respondent.

Before MARIS, BIDDLE, and BUFFINGTON, Circuit Judges.

MARIS, Circuit Judge.

These are petitions for review of a decision of the Board of Tax Appeals sustaining a deficiency in the income tax for the year 1931 of the Hedden Iron Construction Company (hereinafter called Hedden), assessed against the petitioners as transferees of the assets of Hedden.

Bethlehem Steel Corporation (hereinafter called Bethlehem) was given an option to acquire the assets of Hedden. In accordance with a prearranged plan and at the direction...

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