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AMERICAN TRANS-OCEAN N. CORP. v. COMMISSIONER OF INT. R.

No. 54, Docket 23468.

229 F.2d 97 (1956)

AMERICAN TRANS-OCEAN NAVIGATION CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided January 24, 1956.

Attorney(s) appearing for the Case

Murray M. Weinstein, New York City, for petitioner.

L. W. Post, Atty., Dept. of Justice, Washington, D. C. (H. Brian Holland, Asst. Atty Gen., Ellis N. Slack, Atty., Dept. of Justice, Washington, D. C., and Lee A. Jackson, Atty., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before SWAN, FRANK and LUMBARD, Circuit Judges.

LUMBARD, Circuit Judge.

This is an appeal by the taxpayer from a decision of the Tax Court on stipulated facts 13 T.C.M. 839 (1954). The taxpayer is a New York corporation. In 1948 it organized a subsidiary, Amtron Tanker Corporation, for the purpose of acquiring a tanker from the United States Maritime Commission. The subsidiary was organized because the Commission said that a direct purchase by the taxpayer might violate...

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