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STEEL IMPROVEMENT AND FORCE COMPANY v. C. I. R.

No. 14800.

314 F.2d 96 (1963)

The STEEL IMPROVEMENT AND FORGE COMPANY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

March 5, 1963.

Attorney(s) appearing for the Case

Brooks W. Maccracken, Cleveland, Ohio (Robert W. Wheeler, Cleveland, Ohio, on the brief; M. B. & H. H. Johnson, Cleveland, Ohio, of counsel), for petitioner.

Gilbert E. Andrews, Dept. of Justice, Washington, D. C. (John B. Jones, Jr., Acting Asst. Atty. Gen., Lee A. Jackson, Harold C. Wilkenfield, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before MILLER and WEICK, Circuit Judges, and PECK, District Judge.

JOHN W. PECK, District Judge.

The record in this case presents a complicated factual pattern of financial negotiation culminating in a contract. However, that contract, from which the questions here at issue arose, is itself comparatively free from complexity. The petitioning Ohio corporation thereby contracted to sell its fully owned Canadian subsidiary (Canadian Steel Improvement Limited of Etobicoke, Ontario) to High Duty Alloys (Canada) Limited, which was a Canadian...

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