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UINTA LIVESTOCK CORPORATION v. UNITED STATES

No. 7959.

355 F.2d 761 (1966)

UINTA LIVESTOCK CORPORATION, a Wyoming corporation, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals Tenth Circuit.

January 4, 1966.

Attorney(s) appearing for the Case

C. Preston Allen, Salt Lake City, Utah (Ray, Quinney & Nebeker, Salt Lake City, Utah, on the brief), for appellant.

J. Edward Shillingburg, Atty., Dept. of Justice, (John B. Jones, Jr., Acting Asst. Atty. Gen., Lee A. Jackson, Meyer Rothwacks and George F. Lynch, Attys., Dept. of Justice, on the brief), for appellee.

Before MURRAH, Chief Judge, and PICKETT and HILL, Circuit Judges.

HILL, Circuit Judge.

This is an income tax refund suit to recover $88,330.27 of taxes paid for 1948.1

The facts are largely undisputed. The Rees Land and Livestock Company, a large family owned corporation, conducted a sheep operation in Wyoming and a cattle operation in Utah. The sheep portion of the corporation comprised approximately 57% of the assets and was operated by William Rees and certain

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