INTERNATIONAL BEDAUX CO. v. COMMISSIONER OF INT. REV.

No. 191, Docket 22388.

204 F.2d 870 (1953)

INTERNATIONAL BEDAUX CO., Inc. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Second Circuit.

Decided June 4, 1953.


Attorney(s) appearing for the Case

George Link, Jr., New York City (Charles H. Buckley, New York City, on the brief), for petitioner.

James Q. Riordan, New York City (H. Brian Holland, Asst. Atty. Gen., and Ellis N. Slack and L. W. Post, Sp. Assts. to the Atty. Gen., on the brief), for respondent.

Before SWAN, Chief Judge, and CLARK and FRANK, Circuit Judges.


CLARK, Circuit Judge.

Presented by this petition for review is a narrow issue arising out of interesting and peculiar circumstances not likely to be often, if ever, repeated. The question is whether petitioner, a personal holding company, succeeded in making distribution of its income in 1942 so as to avoid the heavy surtax assessed under I.R.C. § 500, 26 U.S.C. § 500. Petitioner was then owned by Mr. and Mrs. Charles E. Bedaux, the husband owning 10 per...

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