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UNITED STATES v. GENERAL GEOPHYSICAL COMPANY

No. 18530.

296 F.2d 86 (1961)

UNITED STATES of America, Appellant, v. GENERAL GEOPHYSICAL COMPANY, Appellee.

United States Court of Appeals Fifth Circuit.

Rehearing Denied December 7, 1961.

Attorney(s) appearing for the Case

Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Washington, D. C., William B. Butler, U. S. Atty., Houston, Tex., Gilbert E. Andrews, Jr., Harry Baum, Attorneys, Department of Justice, Washington, D. C., R. F. Wheless, Jr., Asst. U. S. Atty., Houston, Tex., for appellant.

Homer L. Bruce, Houston, Tex., Baker, Botts, Andrews & Shepherd, Houston, Tex., of counsel, for appellee.

Before RIVES and WISDOM, Circuit Judges, and DAWKINS, Jr., District Judge.

WISDOM, Circuit Judge.

February 25, 1954 General Geophysical Company, the taxpayer, transferred certain depreciable assets having a tax basis of $169,290 and a market value of $746,525 to two of its major stockholders in the redemption of their stock. Later that day the taxpayer reacquired the same assets from the former stockholders in exchange for corporate notes in the amount of $746,525. In its 1954 income tax return the corporation claimed depreciation deductions...

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