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U.S. v. NUNNALLY INVESTMENT CO.

No. 990, October Term, 1940.

316 U.S. 258 (1942)

UNITED STATES v. NUNNALLY INVESTMENT CO.

Supreme Court of United States.

Decided May 11, 1942.

Attorney(s) appearing for the Case

Mr. Arnold Raum, with whom Solicitor General Fahy, Assistant Attorney General Clark, and Mr. J. Louis Monarch and Mrs. Elizabeth B. Davis were on the brief, for the United States.

Mr. W.A. Sutherland for respondent.

MR. JUSTICE FRANKFURTER delivered the opinion of the Court.

This is a suit against the United States to recover taxes for the year 1920. In that year the taxpayer, the respondent here, sold its business and all its assets to another corporation. The consideration consisted of cash and the assumption of certain of the respondent's obligations, including federal taxes for previous years. The purchaser paid part of these taxes in 1920, the remainder in 1921 and 1922...

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