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TRI-LAKES S. S. CO. v. COMMISSIONER OF INTERNAL REVENUE

Nos. 9820-9824.

146 F.2d 970 (1945)

TRI-LAKES S. S. CO. v. COMMISSIONER OF INTERNAL REVENUE, and four other cases.

Circuit Court of Appeals, Sixth Circuit.

January 22, 1945.

Attorney(s) appearing for the Case

Thomas H. Adams, of Detroit, Mich. (Sherwin A. Hill, Thomas H. Adams, and Edward H. Yost, all of Detroit, Mich., on the brief), for petitioners.

S. Dee Hanson, of Washington, D. C. (Samuel O. Clark, Jr., Sewall Key, J. Louis Monarch, and Hilbert P. Zarky, all of Washington, D. C., on the brief) for respondent.

Before SIMONS, ALLEN, and MARTIN, Circuit Judges.

SIMONS, Circuit Judge.

The determinative question in each of these petitions for review, is whether the term "property" includes money within the purview of § 112(b)(6) of the Internal Revenue Code 26 U.S.C.A. Int.Rev.Code, § 112(b)(6), which reads:

"(6) Property received by corporation on complete liquidation of another. No gain or loss shall be recognized upon the receipt by a corporation of property distributed in complete liquidation of another...

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