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COMMISSIONER OF INTERNAL REVENUE v. FERRO-ENAMEL CORP.

No. 9343.

134 F.2d 564 (1943)

COMMISSIONER OF INTERNAL REVENUE v. FERRO-ENAMEL CORPORATION.

Circuit Court of Appeals, Sixth Circuit.

April 7, 1943.

Attorney(s) appearing for the Case

Bernard Chertcoff, of Washington, D. C. (Samuel O. Clark, Jr., Sewall Key, and Bernard Chertcoff, all of Washington, D. C., on the brief), for petitioner.

Sterling Newell, of Cleveland, Ohio (Squire, Sanders & Dempsey, Sterling Newell, and Warren E. Hacker, all of Cleveland, Ohio, on the brief), for respondent.

Before ALLEN, HAMILTON, and McALLISTER, Circuit Judges.

HAMILTON, Circuit Judge.

This is a proceeding to review a decision of the United States Board of Tax Appeals (now the United States Tax Court).

Respondent is an Ohio corporation engaged in manufacturing a substance known as porcelain frit, a material used for coating metal, and its office and principal place of business is in Cleveland, Ohio. Respondent owns seven foreign subsidiaries, all of which are producing companies located in Canada, England, Holland...

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