PHILADELPHIA QUARTZ COMPANY
v.
The UNITED STATES.
PHILADELPHIA QUARTZ COMPANY OF CALIFORNIA
v.
The UNITED STATES.
United States Court of Claims.https://leagle.com/images/logo.png
March 17, 1967.
March 17, 1967.
Attorney(s) appearing for the Case
William R. Reynolds, Philadelphia, Pa., attorney of record, for plaintiffs. Michael F. Beausang, Jr., and MacCoy, Evans & Lewis, Philadelphia, Pa., of counsel.
E. Alan Moorhouse, Washington, D. C., with whom was Asst. Atty. Gen. Mitchell Rogovin, for defendant. Lyle M. Turner and Philip R. Miller, Washington, D. C., of counsel.
Before COWEN, Chief Judge, and LARAMORE, DURFEE, DAVIS, COLLINS, SKELTON, and NICHOLS, Judges.
United States Court of Claims.
OPINION
LARAMORE, Judge.
These claims1 put in issue the character of income resulting from the forfeiture of deposits on returnable steel drums used for the shipment of industrial chemicals. Plaintiffs assert the income is capital gain from the sale, exchange, or involuntary conversion of business assets under section 1231 of the Internal Revenue Code of 1954 under this court's holding in E. I. DuPont De Nemours & Co. v....
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