OGDEN COMPANY v. C. I. R.

No. 7281.

412 F.2d 223 (1969)

The OGDEN COMPANY, Petitioner, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals First Circuit.

As Amended on Denial of Rehearing July 11, 1969.


Attorney(s) appearing for the Case

Walter F. Gibbons, Providence, R. I., with whom Armstrong, Gibbons, Black & Lodge, Providence, R. I., was on brief, for appellant.

Stanley L. Ruby, Atty., Dept. of Justice, with whom Johnnie M. Walters, Asst. Atty. Gen., and Lee A. Jackson and William Friedlander, Attys., Dept. of Justice, were on brief, for appellee.

Before ALDRICH, Chief Judge, McENTEE and COFFIN, Circuit Judges.


COFFIN, Circuit Judge.

This appeal from a Tax Court decision for the government raises the question whether one of several financial transactions between a parent corporation and a wholly owned subsidiary, spanning the years 1960 to 1962, constituted a taxable dividend to the parent. The facts, while clear and largely undisputed, present the problem of determining under which of three transactional shells is lodged the taxable pea.

The taxpayer (hereinafter...

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