COMMISSIONER OF INTERNAL REVENUE v. LEVI

No. 8197.

136 F.2d 366 (1943)

COMMISSIONER OF INTERNAL REVENUE v. LEVI.

Circuit Court of Appeals, Seventh Circuit.

Rehearing Denied June 29, 1943.


Attorney(s) appearing for the Case

Samuel O. Clark, Jr., Sewall Key, J. Louis Monarch, and Bernard Chertcoff, Dept. of Justice, and J. P. Wenchel and Claude R. Marshall, Bureau of Internal Revenue, all of Washington, D. C., for petitioner.

Howe P. Cochran, of Washington, D. C. (Margaret F. Luers, of Washington, D. C., of counsel), for respondent.

Before SPARKS, KERNER, and MINTON, Circuit Judges.


MINTON, Circuit Judge.

The E. M. Rosenthal Jewelry Co., a corporation of the District of Columbia, hereinafter referred to as the Rosenthal Co., was engaged in the wholesale jewelry business. Outlets for the sale of its jewelry were several retail establishments, most of whose stock it owned. For business reasons, the Rosenthal Co. determined to eliminate its connections with the retail establishments by organizing another corporation, called the General Associates...

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