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CHARED CORPORATION v. UNITED STATES

No. 28951.

455 F.2d 928 (1972)

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.

February 9, 1972.

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., Dept. of Justice, Washington, D. C., John O. Jones, Tax Atty., U. S. Dept. of Justice, Fort Worth, Tex., Ann E. Belanger, Lee A. Jackson, Attys., Washington, D. C., for defendant-appellee.

Before JONES, BELL and THORNBERRY, Circuit Judges.

ON PETITION FOR REHEARING OF 446 F.2d 745.

PER CURIAM:

By its petition for rehearing the appellant, Chared Corporation, has asked that the deficiency tax assessment be recomputed and be reduced by excluding from the taxable income upon which the deficiency was based specified sums paid as interest by the parent company to the subsidiary and returned, for the most part, to the parent company as "loans." The contention of...

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