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JAMES HOTEL COMPANY v. C.I.R.

No. 7281.

325 F.2d 280 (1963)

JAMES HOTEL COMPANY, Tower Club, Inc., and Palace Building Company, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Tenth Circuit.

November 29, 1963.

Attorney(s) appearing for the Case

Roy C. Lytle, Oklahoma City, Okl. (Lytle, Soule & Emery, Oklahoma City, Okl., on the brief), for petitioners.

Alec A. Pandaleon, Atty., Dept of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and Melva M. Graney, Attys., Dept of Justice, on the brief), for respondent.

Before PHILLIPS, HILL and SETH, Circuit Judges.

PHILLIPS, Circuit Judge.

This is a petition to review a decision of the Tax Court. It involves corporate income taxes for the fiscal years ending on August 31 in each of the years, 1955, 1956, and 1957. The petitioner, Tower Club, Inc.,1 is a subsidiary of the James Hotel Company.2

The facts, which are not in dispute, are these:

James and Tower Club are corporations organized and existing under...

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