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COMMISSIONER OF INTERNAL REVENUE v. CHASE NAT. BANK

Nos. 233-236.

122 F.2d 540 (1941)

COMMISSIONER OF INTERNAL REVENUE v. CHASE NAT. BANK OF CITY OF NEW YORK (four cases).

Circuit Court of Appeals, Second Circuit.

August 14, 1941.

Attorney(s) appearing for the Case

Samuel O. Clark, Jr., Asst. Atty. Gen. (Sewall Key and Michael H. Cardozo IV, Sp. Assts. to Atty. Gen., of counsel), for petitioner.

Weston Vernon, Jr., of New York City (Timothy N. Pfeiffer, Hugh L. M. Cole, and Jesse R. Fillman, all of New York City, of counsel), for respondent.

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

CHASE, Circuit Judge.

Four petitions to review decisions of the Board of Tax Appeals redetermining deficiencies in the income taxes for 1934 of four separate investment trusts were consolidated and heard together.

The Chase National Bank of the City of New York is the trustee of each trust created by an agreement made with it by the American Depositor Corporation, a New York corporation with its principal office in the City of New York. The Commissioner determined...

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