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FORESUN, INC. v. C. I. R.

No. 15946.

348 F.2d 1006 (1965)

FORESUN, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

July 22, 1965.

Attorney(s) appearing for the Case

Richard Katcher, Cleveland, Ohio, for petitioner.

Jonathan Cohen, Department of Justice, Washington, D. C., Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Edward Heilbronner, Attorneys, Department of Justice, Washington, D. C., on brief, for respondent.

Before WEICK, Chief Judge, and MILLER and PHILLIPS, Circuit Judges.

HARRY PHILLIPS, Circuit Judge.

This is an income tax case involving transactions between two family-owned Ohio corporations and Mrs. Ada Osborn, who is the mother or mother-in-law of the officers and stockholders of petitioner. The taxpayer, Foresun, Inc., is referred to herein as "petitioner." The other corporation, The Stalwart Rubber Company, is referred to as "Stalwart." Mrs. Osborn's husband, now deceased, was the principal stockholder of Stalwart during the...

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