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SEATTLE HARDWARE COMPANY v. SQUIRE

No. 12259.

181 F.2d 188 (1950)

SEATTLE HARDWARE COMPANY, Appellant, v. Clark SQUIRE, Collector of Internal Revenue, Appellee.

United States Court of Appeals Ninth Circuit.

April 24, 1950.

Attorney(s) appearing for the Case

H. B. Jones, A. R. Kehoe and R. B. Hooper, Seattle, Wash., for appellant.

Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack, S. Dee Hanson, Sp. Assts. to Atty. Gen., J. Charles Dennis, U. S. Atty., Harry Sager, Asst. U. S. Atty., Tacoma, Wash., Thomas R. Winter, Sp. Asst. to Chief Coun., Bureau of Int. Revenue, Seattle, Wash., for appellee.

Before HEALY, BONE, and POPE, Circuit Judges.

PER CURIAM.

We think the trial court correctly disposed of this matter. Appellant argues earnestly that the decision is at variance with National Carbide Corp. v. Commissioner, 336 U.S. 422, 69 S.Ct. 726, but a study of the latter opinion persuades us that the situation it dealt with is easily distinguishable. In the National Carbide case the subsidiary corporation utilized were major operating and manufacturing companies set up on...

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