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CHARED CORPORATION v. UNITED STATES

No. 28951.

446 F.2d 745 (1971)

CHARED CORPORATION, Transferee of the British-American Oil Products Company, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

July 13, 1971.

Attorney(s) appearing for the Case

J. W. Bullion, Buford P. Berry, Dallas, Tex., for plaintiff-appellant.

Eldon B. Mahon, U.S. Atty., Martha Joe Stroud, Asst. U.S. Atty., Dallas, Tex., Stanley F. Krysa, Trial Atty., Department of Justice, Washington, D.C., John O. Jones, Tax Atty., U.S. Department of Justice, Fort Worth, Tex., Johnnie M. Walters, Asst. Atty. Gen., Ann E. Belanger, Lee A. Jackson, Attys., U.S. Dept. of Justice, Washington, D.C., William A. Friedlander, Washington, D.C., for defendant-appellee.

Before JONES, BELL and THORNBERRY, Circuit Judges.

PER CURIAM.

The appellant, Chared Corporation, seeks to recover taxes paid to the United States. The issue before this Court is stated by the appellant in the following language: "Whether advances made by The British-American Oil Producing Company to its Canadian parent corporation, The British-American Oil Company, Limited were loans or dividends. The district court held that the advances were dividends as to which The British-American Oil Producing Company should...

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