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  5. 139 F.2d 419 (1943)
 

HELVERING v. SCOTTISH AMERICAN INV. CO.

Nos. 5122-5124.

139 F.2d 419 (1943)

HELVERING, Com'r of Internal Revenue, v. SCOTTISH AMERICAN INV. CO., Limited. SAME v. SECOND BRITISH ASSETS TRUST, Limited. SAME v. BRITISH ASSETS TRUST, Limited.

Circuit Court of Appeals, Fourth Circuit.

November 8, 1943.

Attorney(s) appearing for the Case

Warren F. Wattles, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., Sewall Key, Samuel H. Levy, and Helen Goodner, Sp. Assts. to Atty. Gen., on the brief), for petitioner.

Marion N. Fisher, of New York City (William H. Harrar, of New York City, on the brief), for respondents.

Before PARKER, SOPER, and DOBIE, Circuit Judges.

DOBIE, Circuit Judge.

Scottish American Investment Company, Limited, British Assets Trust, Limited, and Second British Assets Trust, Limited, are all corporations organized under the laws of Great Britain. Each has its principal office in Edinburgh, Scotland. For convenience, the three corporations are hereinafter called the Trusts. The Trusts were engaged in the business of investing the funds of their security-holders. These investments were made primarily for the...

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