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RAFFOLD PROCESS CORP. v. COMMISSIONER OF INT. REV.

No. 4066.

153 F.2d 168 (1946)

RAFFOLD PROCESS CORPORATION et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, First Circuit.

January 11, 1946.

Attorney(s) appearing for the Case

Robert C. McKay, of Boston, Mass., for petitioners.

Eugene E. Beyer, Sp. Asst. to Atty. Gen., (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, A. F. Prescott, and Muriel S. Paul, Sp. Assts. to Atty. Gen., and J. P. Wenchel, Chief Counsel, and John M. Morawski, Sp. Atty., Bureau of Int. Rev., both of Washington, D. C., on the brief), for respondent.

Before MAGRUDER, MAHONEY, and WOODBURY, Circuit Judges.

WOODBURY, Circuit Judge.

These consolidated petitions for review of two decisions of the Tax Court of the United States raise the question of the deductibility from income, personal holding company, and declared value excess profits taxes of advances made by the two petitioning corporations to a third under the following circumstances.

Harold R. Rafton, formerly the owner of a chemical laboratory specializing in problems arising from the use of carbonate fillers...

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