HATFRIED, INC. v. COMMISSIONER OF INTERNAL REV.

No. 9180.

162 F.2d 628 (1947)

HATFRIED, Inc., et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

Decided June 11, 1947.


Attorney(s) appearing for the Case

Abraham L. Shapiro, of Philadelphia, Pa., and Louis Stein, of Union City, N. J. (Shapiro & Shapiro, of Philadelphia, Pa., on the brief), for petitioners.

Irving I. Axelrod, of Washington, D. C. (Sewall Key, Acting Asst. Atty. Gen., A. F. Prescott, Sp. Asst. to the Atty. Gen., on the brief), for respondent.

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


KALODNER, Circuit Judge.

This appeal is taken from the decision of the Tax Court.

Two questions are presented: (1) whether the taxpayer should be classified as a personal holding company within the meaning of Sections 501 and 502(f) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev. Code, §§ 501, 502(f); (2) whether, if the taxpayer is taxable as a personal holding company, there was a proper imposition of the penalty imposed by Section 291 of the...

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