BANKERS GUARANTEE TITLE & TRUST COMPANY, Plaintiff-Appellant,
v.
UNITED STATES of America, Defendant.
BANKERS GUARANTEE TITLE & TRUST COMPANY, Plaintiff-Cross-Appellee,
v.
UNITED STATES of America, Defendant-Cross-Appellant.
United States Court of Appeals Sixth Circuit.https://leagle.com/images/logo.png
November 28, 1969.
November 28, 1969.
Attorney(s) appearing for the Case
David H. Wilson, Akron, Ohio, for Bankers Guarantee Title & Trust; Norman S. Carr, Brouse, McDowell, May & Birece, Akron, Ohio, on brief.
William L. Goldman, Atty., Dept. of Justice, Washington, D. C., for the United States; Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson, Thomas L. Stapleton, Attys., Dept. of Justice, Washington, D. C., on brief; Bernard J. Stuplinski, U. S. Atty., Carl H. Miller, Asst. U. S. Atty., Cleveland, Ohio, of counsel.
Before WEICK and PECK, Circuit Judges, and MACHROWICZ, District Judge.
United States Court of Appeals Sixth Circuit.
PER CURIAM.
This is an action for refund of income taxes paid by plaintiff Bankers Title and Trust Company. Bankers is engaged in the mortgage banking business in Akron, Ohio. As a mortgage banker it institutes mortgage loans and sells the mortgages to institutional investors. For this service it receives a discount fee from the investor and an origination fee from the borrower for the generation of the mortgage loan. Bankers...
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