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PIONEER PARACHUTE CO. v. COMMISSIONER OF INTERNAL REV.

No. 194, Docket 20380.

162 F.2d 249 (1947)

PIONEER PARACHUTE CO., Inc., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

June 24, 1947.

Attorney(s) appearing for the Case

Edmund S. Kochersperger, of Washington, D. C. (Pomeroy Day and Robinson, Robinson & Cole, all of Hartford, Conn., of counsel), for petitioner.

Sewall Key, Acting Asst. Atty. Gen., and Lee A. Jackson and L. W. Post, Sp. Assts. to Atty. Gen., for respondent.

Before L. HAND, SWAN, and CLARK, Circuit Judges.

SWAN, Circuit Judge.

The sole question presented by this petition is whether Pioneer Parachute Company, Inc., a Connecticut corporation, and Cheney Brothers, also a Connecticut corporation, were an "affiliated group," as defined in § 730(d) of the Internal Revenue Code, as amended, 26 U.S.C.A. Int.Rev. Code, § 730(d), from March 30 to December 31, 1941, and privileged as such to file a consolidated excess profits tax return for that period. As applied to...

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