DRYBROUGH v. COMMISSIONER OF INTERNAL REVENUE

Nos. 12747, 12748.

238 F.2d 735 (1956)

F. W. DRYBROUGH, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. L. N. SIMPSON, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

December 3, 1956.


Attorney(s) appearing for the Case

Donald V. Hunter, Washington, D. C., Miller & Chevalier, Washington, D. C., of counsel, for petitioners.

S. Dee Hanson, Washington, D. C., Charles K. Rice, Lee A. Jackson, Robert N. Anderson, Dept. of Justice, Washington, D. C., on the brief, for respondent.

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


STEWART, Circuit Judge.

These are petitions to review decisions of the Tax Court in consolidated proceedings. The facts are set out in detail in that court's findings and opinion. 1955, 23 T.C. 1105 (sub nom. United Mercantile Agencies, Inc.).

Stripped of details, the facts are appallingly simple. The petitioners owned or controlled all the stock of a corporation engaged in the business of conducting a collection and mercantile...

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