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AMERICAN PIPE & STEEL CORP. v. COMMISSIONER OF INT. REV.

No. 15174.

243 F.2d 125 (1957)

AMERICAN PIPE & STEEL CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

Rehearing Denied June 4, 1957.

Attorney(s) appearing for the Case

M. Mitchell Bourquin, George DeLew, William B. Boone, San Francisco, Cal., for petitioner.

Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, I. Henry Kutz, Walter R. Gelles, Joseph F. Goetten, Washington, D. C., for respondent.

Before ORR, FEE, and BARNES, Circuit Judges.

ORR, Circuit Judge.

Petitioner is a corporation principally engaged in the steel fabricating business. In 1943 it acquired the capital stock of a corporation known as Palos Verdes Estates, Inc., hereafter Palos Verdes, and that company became a wholly-owned subsidiary of American Pipe. Thereafter, American Pipe and Palos Verdes filed consolidated returns for the years 1943, 1944, 1945, and 1946. The Commissioner of Internal Revenue determined a deficiency in the taxes...

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