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COAST QUALITY CONSTRUCTION CORP. v. UNITED STATES

No. 71-2624.

463 F.2d 503 (1972)

COAST QUALITY CONSTRUCTION CORPORATION and Subsidiaries, Plaintiffs-Appellees, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

July 11, 1972.

Attorney(s) appearing for the Case

Gerald J. Gallinghouse, U. S. Atty., New Orleans, La., Charles G. Barnett, Atty. Tax Division, Dept. of Justice, Dallas, Tex., Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, Jr., Meyer Rothwacks, Atty., Carleton D. Powell, Harry Baum, Tax Div., Dept. of Justice, Washington, D. C., Fred B. Ugast, Acting Asst. Atty. Gen., for defendant-appellant.

A. J. Schmitt, Jr., of Beard, Blue, Schmitt & Treen, New Orleans, La., for plaintiffs-appellees.

Before WISDOM, GODBOLD and RONEY, Circuit Judges.

GODBOLD, Circuit Judge:

Two noted commentators have forecast that applying the "substantially the same trade or business" requirement of § 382(a) (1) (C) of the Internal Revenue Code would present problems that would "be difficult to resolve in practice" and would "practically insure a high level of uncertainty." B. Bittker & J. Eustice, Federal Income Taxation of Corporations & Shareholders § 16.22, at 16-53 (3d ed. 1971). This appeal evidences...

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