BRENTWOOD HOMES, INC. v. UNITED STATES

Nos. 1531-1533.

240 F.Supp. 378 (1965)

BRENTWOOD HOMES, INC., Crabtree Corporation and J. R. Land Company v. UNITED STATES of America.

United States District Court E. D. North Carolina, Raleigh Division.

April 16, 1965.


Attorney(s) appearing for the Case

Poyner, Geraghty, Hartsfield & Townsend, N. A. Townsend, Jr., Thomas L. Norris, Jr., Raleigh, N. C., for plaintiffs.

Robert H. Cowen, U. S. Atty., Raleigh, N. C., Norman Goldin, Atty., Tax Division, Dept. of Justice, for defendant.


HAYES, District Judge.

These cases involve tax liabilities of multiple corporations under a single control. The Commissioner determined that the three corporations were under single control and pursuant to section 482 of the Internal Revenue Act, allocated the entire income to the first corporation. These suits were brought to recover the taxes paid, alleging the Commissioner had abused his discretion by acting arbitrarily, capriciously and unreasonably in making...

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