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S. LOEWENSTEIN & SON v. COMMISSIONER OF INTERNAL REV.

Nos. 12352, 12353.

222 F.2d 919 (1955)

S. LOEWENSTEIN & SON, a Michigan Corporation, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. S. LOEWENSTEIN & SON, a Michigan Corporation, Respondent.

United States Court of Appeals Sixth Circuit.

May 31, 1955.

Attorney(s) appearing for the Case

Sylvan Rapaport, Detroit, Mich., Joseph H. Jackier, Detroit, Mich., on brief, for S. Loewenstein & Son.

Marvin E. Frankel, Washington, D. C., H. Brian Holland, Ellis N. Slack, Hilbert P. Zarky, Harry Baum, Washington, D. C., on brief, for Commissioner.

Before MARTIN, MILLER and STEWART, Circuit Judges.

PER CURIAM.

Both the taxpayer, S. Loewenstein & Son, a Michigan corporation, and the Commissioner seek a review of the ruling of the Tax Court that there was a deficiency in excess profits tax for the year 1945 in the amount of $58,004.89. The taxpayer is hereinafter referred to as the petitioner.

Petitioner was engaged in the business of purchasing and slaughtering beef cattle and selling the beef to retail stores in the Detroit area. It filed its returns...

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