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HANSON v. UNITED STATES

Civ. Nos. 637-638.

338 F.Supp. 602 (1971)

Leslie L. HANSON, individually and as executor of the Estate of Lillian L. Hanson, Deceased, Plaintiff, v. UNITED STATES of America, Defendant. Louise MERSEN, individually and Louise Mersen, et al., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. Montana, Billings Division.

December 29, 1971.

Attorney(s) appearing for the Case

Crowley, Kilbourne, Haughey, Hanson & Gallagher, Billings, Mont., for plaintiffs.

Johnnie M. Walters, Asst. Atty. Gen., Jerome Fink, and James P. Parker, Attys., Dept. of Justice, Washington, D. C., and Otis L. Packwood, U. S. Atty., Billings, Mont., for defendant.

ORDER AND MEMORANDUM OPINION

JAMESON, District Judge.

These actions were brought pursuant to 28 U.S.C. § 1346(a) (1), to recover income taxes paid by the plaintiffs for the year 1955.1 At issue in each case is whether a distribution of stock of Hanson-Mersen Motors, Inc. to the shareholders of H-M Corporation qualified for tax free status as a "spin-off" under Section 355 of...

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