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BROWN GROUP, INC. v. C.I.R.

No. 95-2110.

77 F.3d 217 (1996)

BROWN GROUP, INC. and its Subsidiaries, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided January 25, 1996.

Rehearing and Suggestion for Rehearing Denied April 16, 1996.

Attorney(s) appearing for the Case

Thomas C. Walsh, St. Louis, Missouri, argued (Harold G. Blatt, St. Louis, Missouri, and Michael F. Solomon, Washington, DC, on the brief), for appellant.

Frank P. Cihlar, Washington, DC, argued (Loretta C. Argrett as Assistant Attorney General, Gary R. Allen and David English Carmack, Washington, DC, on the brief), for appellee.

Before FAGG, Circuit Judge, GARTH, Senior Circuit Judge, WOLLMAN, Circuit Judge.

Rehearing and Suggestion for Rehearing En Banc Denied April 16, 1996.*

GARTH, Senior Circuit Judge.

This is an appeal from the en banc decision by the United States Tax Court (the "Tax Court"), assessing taxes against appellant, the Brown Group, Inc. ("the Brown Group") and its subsidiaries, on the commission distributions received by the Brown Group's wholly-owned Cayman Islands subsidiary, Brown Cayman, Ltd. ("BCL"), under...

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