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GRAIN BELT TRANSPORTATION CO. v. UNITED STATES

No. 71-1660.

465 F.2d 1202 (1972)

GRAIN BELT TRANSPORTATION CO., INC., a Missouri corporation, Appellant, v. The UNITED STATES of America, Appellee.

United States Court of Appeals, Tenth Circuit.

Rehearing Denied September 13, 1972.

Attorney(s) appearing for the Case

Warren H. Sapp, III, Kansas City, Mo. (Tom B. Kretsinger, Warren H. Sapp, Kretsinger & Kretsinger, Kansas City, Mo., on the brief), for appellant.

J. Townsend, Washington, D. C., (Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Grant W. Wiprud, William S. Estabrook, III, Attys., Tax Div., Dept. of Justice, Washington, D. C., on the brief), for appellee.

Before JONES, McWILLIAMS and BARRETT, Circuit Judges.

JONES, Circuit Judge:

The Grain Belt Transportation Co., Inc., herein referred to as the taxpayer, is a Missouri corporation with its principal place of business in Kansas. It holds certificates from the Interstate Commerce Commission permitting it to carry on the business of an interstate common carrier of freight by motor vehicles in twelve states. It owns no equipment, but leases its vehicles from individual owners pursuant...

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