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MAIN STREET BANK v. NEE

Nos. 3440, 3470.

75 F.Supp. 597 (1948)

MAIN STREET BANK et al. v. NEE, Collector of Internal Revenue. LINWOOD SECURITIES CO. et al. v. SAME.

District Court, W. D. Missouri, W. D.

January 2, 1948.

Attorney(s) appearing for the Case

Stinson, Mag, Thomson, McEvers & Fizzell, of Kansas City, Mo. (Reece A. Gardner and G. Lee Burns, both of Kansas City, Mo., and John W. Reed, of Norman, Okl., of counsel), for plaintiffs.

Sam M. Wear, U. S. Atty., and Sam Hargus, Asst. U. S. Atty., both of Kansas City, Mo., for defendant.

REEVES, District Judge.

On June 21st of this year a memorandum opinion was filed in the above cases, 72 F.Supp. 922. In this opinion it was held that the trust arrangements in both cases were of such nature as to constitute an association contemplated by the Regulations of the Commissioner of Internal Revenue, and, as such, were taxable as corporations.

The entire case has been again reviewed. It appears from a careful...

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