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MACKINAC ISLAND CARRIAGE TOURS, INC. v. C. I. R.

No. 71-1452.

455 F.2d 98 (1972)

MACKINAC ISLAND CARRIAGE TOURS, INC., a Michigan corporation, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Sixth Circuit.

February 9, 1972.

Attorney(s) appearing for the Case

Walter J. Murray, Detroit, Mich., for petitioner.

James H. Bozarth, Dept. of Justice, Tax Div., Washington, D. C., for respondent; Fred B. Ugast, Acting Asst. Atty. Gen., Meyer Rothwacks, Richard W. Perkins, Attys., Tax Div., Dept. of Justice, Washington, D. C., on brief.

Before MILLER and KENT, Circuit Judges, and O'SULLIVAN, Senior Circuit Judge.

KENT, Circuit Judge.

This case has been previously before this Court. 419 F.2d 1103 (6th Cir., 1970). The facts are sufficiently stated in the previous opinion:

The taxpayer is a Michigan corporation which operates horse drawn carriage tours on Mackinac Island. Such carriages, except for bicycles, constitute virtually the only means of transportation on the island. For many years the State of Michigan and the City of Mackinac...

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