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J. R. LAND COMPANY v. UNITED STATES

Nos. 10194-10196.

361 F.2d 607 (1966)

J. R. LAND COMPANY, Appellant, v. UNITED STATES of America, Appellee. CRABTREE CORPORATION, Appellant, v. UNITED STATES of America, Appellee. BRENTWOOD HOMES, INC., Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals Fourth Circuit.

Decided May 3, 1966.

Attorney(s) appearing for the Case

N. A. Townsend, Jr., Raleigh, N. C. (Thomas L. Norris, Jr., and Poyner, Geraghty, Hartsfield & Townsend, Raleigh, N. C., on brief), for appellants.

Richard J. Heiman, Atty., Dept. of Justice (Richard M. Roberts, Acting Asst. Atty. Gen., Meyer Rothwacks, Atty., Dept. of Justice, and Robert H. Cowen, U. S. Atty., on brief), for appellee.

Before BOREMAN, BRYAN and J. SPENCER BELL, Circuit Judges.

J. SPENCER BELL, Circuit Judge:

These cases involve the tax liability of multiple corporations under single control. The Commissioner determined that the three corporations were under single control, and pursuant to section 482 of the Internal Revenue Act, 26 U.S.C.A. § 482, allocated the entire income to the first corporation formed. These suits were brought to recover the taxes paid on the grounds that the Commissioner

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