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SIMONSEN INDUSTRIES v. COMMISSIONER OF INTERNAL REV.

No. 11904.

243 F.2d 407 (1957)

SIMONSEN INDUSTRIES, Inc., Edward H. Simonsen and Ethel G. Simonsen, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Seventh Circuit.

April 22, 1957.

Attorney(s) appearing for the Case

Philip D. Caloger, Harold V. Snyder, Chicago, Ill., for petitioner.

Charles K. Rice, Asst. Atty. Gen., Walter Akerman, Jr., Lee A. Jackson, Attorneys, Department of Justice, Washington, D. C., for respondent.

Before DUFFY, Chief Judge, and FINNEGAN and LINDLEY, Circuit Judges.

LINDLEY, Circuit Judge.

In 1946 the taxpayers, with others, entered into an agreement whereby they became joint participants in the Simonsen Wire Syndicate, for the purpose of acquiring, financing and marketing certain surplus war stocks of wire from the War Assets Corporation. Believing that this merchandise could be bought and sold at a profit, between May and November, 1946, the syndicate purchased property from the Government...

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