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TENNESSEE, ALABAMA & G. RY. CO. v. COMMISSIONER OF INT. R.

No. 11220.

187 F.2d 826 (1951)

TENNESSEE, ALABAMA & GEORGIA RY. CO. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Sixth Circuit.

March 14, 1951.

Attorney(s) appearing for the Case

Wilmurt B. Linker, New York City, Claude A. Hope, Wilmurt B. Linker, and James C. Mulligan, all of New York City, on brief; Delafield, Marsh & Hope, New York City, of counsel, for petitioner.

Carlton Fox, Washington, D. C., Theron Lamar Caudle, Ellis N. Slack, and Carlton Fox, all of Washington, D. C., on brief, for respondent.

Before HICKS, Chief Judge, and SIMONS and MARTIN, Circuit Judges.

MARTIN, Circuit Judge.

This tax review involving complicated transactions and the applicability or inapplicability of numerous sections and subsections of the Internal Revenue Code analyzes to a single issue: Did the United States Tax Court, in determining the equity invested capital of a newly organized railroad corporation for excess profits tax purposes, correctly hold that a series of transactions leading to its set-up constituted integrated steps and parts of...

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