HELVERING v. CREDIT ALLIANCE CORPORATION

No. 4801.

122 F.2d 361 (1941)

HELVERING, Commissioner of Internal Revenue, v. CREDIT ALLIANCE CORPORATION.

Circuit Court of Appeals, Fourth Circuit.

Writ of Certiorari Granted November 24, 1941.


Attorney(s) appearing for the Case

Arthur A. Armstrong, Sp. Asst. to the Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Lee A. Jackson, Sp. Assts. to the Atty. Gen., on the brief), for petitioner.

Newell W. Ellison, of Washington, D. C. (Jack J. Levinson, and Christopher S. Sargent, both of New York City, on the brief), for respondent.

Before SOPER, DOBIE, and NORTHCOTT, Circuit Judges.


Writ of Certiorari Granted November 24, 1941. See ___ U.S. ___, 62 S.Ct. 301, 86 L.Ed. ___.

SOPER, Circuit Judge.

In the course of a complete liquidation in 1936, the Credit Alliance Corporation, the taxpayer, made a distribution to the Commercial Credit Company, its parent corporation, of earnings and profits accrued since February 28, 1913. No gain or loss resulted to the parent corporation from the distribution because of the provisions of Section 112(b...

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