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LOUISVILLE CHAIR COMPANY v. UNITED STATES

No. 14386.

296 F.2d 621 (1961)

LOUISVILLE CHAIR COMPANY, Inc., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals Sixth Circuit.

November 24, 1961.

Attorney(s) appearing for the Case

Charles F. Wood, Louisville, Ky., Bernard H. Barnett, of Greenebaum, Barnett, Wood & Doll, Louisville, Ky., on brief, for appellant.

Morton K. Rothschild, Washington, D. C., Louis F. Oberdorfer, Lee A. Jackson, Robert N. Anderson and Louise Foster, Dept. of Justice, Washington, D. C., and William B. Jones, U. S. Atty., Louisville, Ky., on brief, for appellee.

Before MARTIN and CECIL, Circuit Judges, and DARR, District Judge.

PER CURIAM.

The three Conrad brothers were sole shareholders and officers of the Louisville Chair Company, Inc. In the taxable years involved in this suit brought by them for refund of income and excess profits taxes, the brothers received very substantial salaries and commissions, and at the end of the taxable years each received a bonus of $10,000.

The Commissioner of Internal Revenue decided that, inasmuch as the brothers owned all the corporate stock,...

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