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LYDIADE INVESTMENT TRUST v. UNITED STATES

No. 67 C 51(1).

289 F.Supp. 507 (1968)

LYDIADE INVESTMENT TRUST, a corporation, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court E. D. Missouri, E. D.

August 1, 1968.

Attorney(s) appearing for the Case

G. A. Buder, Jr., and Richard O. Roberts, St. Louis, Mo., for plaintiff.

Veryl L. Riddle, U. S. Atty., Irvin L. Ruzicka, Asst. U. S. Atty., St. Louis, Mo., Elliott H. Kajan, Atty., Tax Div., U. S. Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM OPINION

HARPER, Chief Judge.

This is an action for recovery of corporate income and personal holding company taxes paid by the plaintiff, Lydiade Investment Trust. The Commissioner found deficiencies for the years 1960 and 1961 resulting from his determination that certain amounts received in those years were interest income, offset in part by his allowance of certain payments made by the plaintiff as interest expense. The plaintiff declared and...

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