KOHLER-CAMPBELL CORPORATION v. UNITED STATES

No. 8361.

298 F.2d 911 (1962)

KOHLER-CAMPBELL CORPORATION, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals Fourth Circuit.

Decided January 4, 1962.


Attorney(s) appearing for the Case

Thomas A. Litsch, New York City (Frank C. Patton, Morganton, N. C., and Kenneth F. Clark, New York City, on the brief) for appellant.

John F. Murray, Atty., Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Harry Baum and Richard J. Heiman, Attys., Dept. of Justice, Washington, D. C., and Hugh E. Monteith, U. S. Atty., Sylva, N. C., on the brief) for appellee.

Before BOREMAN, BRYAN and BELL, Circuit Judges.


J. SPENCER BELL, Circuit Judge.

This is an appeal from a judgment of the District Court involving a deficiency in Federal income tax for the year 1954. The question for decision is whether the sum of $15,000.00 received by the taxpayer in 1954 was taxable to it as income of that year.

During the Spring and Summer of 1954, Kohler & Campbell, Inc., a New York corporation engaged in manufacturing pianos and organs, sought a new manufacturing site. It located...

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