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COTAN CORPORATION v. COMMISSIONER OF INTERNAL REV.

No. 8549.

147 F.2d 509 (1945)

COTAN CORPORATION v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

Decided February 7, 1945.

Attorney(s) appearing for the Case

Kenneth Carroad, of New York City (Joshua Peterfreund, of New York City, on the brief), for petitioner.

MaryHelen Wigle, of Washington, D. C. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and A. F. Prescott, Sp. Assts. to the Atty. Gen., on the brief), for respondent.

Before GOODRICH and McLAUGHLIN, Circuit Judges and KALODNER, District Judge.

McLAUGHLIN, Circuit Judge.

This petition for review concerns deficiencies in unjust enrichment tax for the calendar year 1936, under Title III, Section 501 of the Revenue Act of 1936, 26 U.S.C.A. Int.Rev.Acts, page 944.1

Petitioner is a manufacturer of leatherized textiles and rubberized fabrics. It buys raw cotton cloth of various constructions and weights. In its original state, a lot or roll of this can be traced to a particular...

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