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OVERLAND CORPORATION v. C. I. R.

Nos. 14673, 14674.

316 F.2d 777 (1963)

The OVERLAND CORPORATION (Formerly Willys-Overland Motors, Inc.), Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. The OVERLAND CORPORATION (Formerly Willys-Overland Motors, Inc.), Respondent.

United States Court of Appeals Sixth Circuit.

May 7, 1963.

Attorney(s) appearing for the Case

Jay O. Kramer, Milton M. Bernard, New York City, for petitioner; Thomas J. Lynch, Washington, D. C., George W. Ritter, Milton C. Boesel, Toledo, Ohio, on the brief.

Harry Marselli, Dept. of Justice, Washington, D. C., for respondent; John B. Jones, Jr., Acting Asst. Atty. Gen., Lee A. Jackson, Harold C. Wilkenfeld, Attys., Dept. of Justice, Washington, D. C., on the brief.

Before MILLER, Circuit Judge, BOYD, District Judge, and STARR, Senior District Judge.

STARR, Senior District Judge.

The Overland Corporation has petitioned for review of the decision of the Tax Court of the United States rendered April 10, 1961, 34 T.C. 1001, No. 105, denying its claims for relief and refund of certain excess profits taxes. The Commissioner of Internal Revenue has also petitioned for review of certain provisions of the Tax Court's decision. The Tax Court's findings of fact, opinion, and decision were...

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