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TOLEDO HOME FEDERAL SAVINGS & LOAN ASS'N v. UNITED STATES

No. 15054.

318 F.2d 292 (1963)

TOLEDO HOME FEDERAL SAVINGS AND LOAN ASSOCIATION, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals Sixth Circuit.

June 6, 1963.

Attorney(s) appearing for the Case

James F. Kennedy, Jr., Toledo, Ohio, Marshall, Melhorn, Bloch & Belt, Arnold F. Bunge, Sr., Toledo, Ohio, on brief, for appellant.

Joseph Howard, Washington, D. C., Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Melva M. Graney, Earl J. Silbert, Attorneys, Department of Justice, Washington, D. C., Merle M. McCurdy, U. S. Atty., John G. Mattimoe, Asst. U. S. Atty., Toledo, Ohio, on brief, for appellees.

Before MILLER and O'SULLIVAN, Circuit Judges, and PRETTYMAN, Senior Circuit Judge.

SHACKELFORD MILLER, Jr., Circuit Judge.

This is an action for the refund of Federal income taxes paid for the years 1952, 1953, and 1954.

During the taxable years involved, The Home Building and Savings Company, an Ohio corporation, operated a perpetual building and loan association under the laws of Ohio. In February 1959 it converted to a federal savings and loan association and as a result, became the Toledo Home Federal Savings and Loan Association, the...

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