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LOCAL FINANCE CORPORATION v. C. I. R.

Nos. 16840-16850.

407 F.2d 629 (1969)

LOCAL FINANCE CORPORATION, Local Finance Corporation of South Marion, Local Finance Corporation of Elkhart, Local Finance Corporation of Gas City, Local Finance Corporation of Rushville, Local Finance Corporation of Danville, Local Finance, Inc., Local Finance Co., Inc. of Gary, Local Finance Company, Inc., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant, v. GUARDIAN AGENCY, INC., Beneficial Insurance Agency, Inc., Petitioners-Appellees.

United States Court of Appeals Seventh Circuit.

Rehearing Denied April 9, 1969.

Attorney(s) appearing for the Case

Stephen A. Milwid, John K. O'Connor, Max E. Meyer, Wilbur S. Legg, Chicago, Ill., Lord, Bissell & Brook, Chicago, Ill., of counsel, for Local Finance Corp.

Mitchell Rogovin, Asst. Atty. Gen., Stuart A. Smith, Attorney, Department of Justice, Tax Division, Washington, D. C., Lee A. Jackson, J. Edward Shillingburg, Attorneys, Department of Justice, Washington, D. C., for C.I.R.

Before SWYGERT, FAIRCHILD and KERNER, Circuit Judges.

SWYGERT, Circuit Judge.

We are asked to review a decision of the Tax Court upholding the assessment of income tax deficiencies by the Commissioner of Internal Revenue.1 This case presents the question whether the Tax Court was correct in holding that the Commissioner's allocation to the petitioners, Local Finance Corporation and its subsidiaries pursuant to his authority under Int.Rev.Code of 1954, § 482,2

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