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HELVERING v. JANE HOLDING CORPORATION

Nos. 11520, 11522.

109 F.2d 933 (1940)

HELVERING, Com'r of Internal Revenue, v. JANE HOLDING CORPORATION. MALLINCKRODT et al. v. HELVERING, Com'r of Internal Revenue.

Circuit Court of Appeals, Eighth Circuit.

Rehearing Denied March 16, 1940.

Attorney(s) appearing for the Case

L. W. Post, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Newton K. Fox, Sp. Assts. to Atty. Gen., on the brief), for Guy T. Helvering, Commissioner of Internal Revenue.

Harry W. Kroeger, of St. Louis, Mo. (Daniel N. Kirby, of St. Louis, Mo., on the brief), for Jane Holding Corporation and Edward Mallinckrodt, Jr., et al.

Before WOODROUGH and THOMAS, Circuit Judges, and NORDBYE, District Judge.

WOODROUGH, Circuit Judge.

These cases are before the court on separate petitions for review of two decisions of the Board of Tax Appeals rendered in proceedings instituted by two petitions for re-determination of income tax liability as determined by two separate deficiency letters issued by the Commissioner of Internal Revenue. One proceeding was instituted in the Board of Tax Appeals by petition for re-determination filed by Jane Holding Corporation, petitioner...

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