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CARRAGAN v. COMMISSIONER OF INTERNAL REVENUE

No. 212, Docket 22238.

197 F.2d 246 (1952)

CARRAGAN v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Second Circuit.

Decided May 12, 1952.

Attorney(s) appearing for the Case

John G. Turnbull, New York City, for petitioner.

Ellis N. Slack, Washington, D. C. (Robert N. Anderson and Morton K. Rothschild, Washington, D. C., of counsel), for respondent.

Before SWAN, Chief Judge, and AUGUSTUS N. HAND and FRANK, Circuit Judges.

FRANK, Circuit Judge.

1. Petitioner was employed by the Japanese-owned Takamine corporation and its immediate predecessor from 1916 until its liquidation in 1942. On May 20, 1942, when the liquidation had been largely completed, its board of directors adopted the following resolution:

"WHEREAS, the liquidation of Takamine Corporation has been substantially completed; and "WHEREAS, in accordance with precedent, the directors deem it fitting and proper...

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