Attorney(s) appearing for the Case
Percy W. Phillips, Washington, D. C. (Ivins, Phillips & Barker, Washington, D. C., on the brief), for petitioner.
Meyer Rothwacks, Atty., Dept. of Justice, Washington, D. C. (Andrew F. Oehmann, Acting Asst. Atty. Gen., and Lee A. Jackson and Joseph F. Goetten, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.
Before HINCKS, LUMBARD and MOORE, Circuit Judges.
United States Court of Appeals Second Circuit.
HINCKS, Circuit Judge.
This is a petition to review an order of the Tax Court, which upheld the Commissioner's deficiency assessment of $2,101,823.39 in income and excess profits tax against the petitioner, Jordan Marsh Company. There is no dispute as to the facts, which were stipulated before the Tax Court and which are set forth in substance below.
The transactions giving rise to the dispute were conveyances by the petitioner in 1944 of the fee of two parcels...
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