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CROCKER v. MALLEY

No. 649.

249 U.S. 223 (1919)

39 S.Ct. 270

63 L.Ed. 573

CROCKER ET AL., TRUSTEES, v. MALLEY, COLLECTOR OF INTERNAL REVENUE.

Supreme Court of United States.

Decided March 17, 1919.

Attorney(s) appearing for the Case

Mr. Felix Rackemann, with whom Mr. Harrison M. Davis was on the brief, for petitioners:

Mr. Assistant Attorney General Frierson for respondent:

MR. JUSTICE HOLMES delivered the opinion of the court.

This is an action to recover taxes paid under protest to the Collector of Internal Revenue by the petitioners, the plaintiffs. The taxes were assessed to the plaintiffs as a joint-stock association within the meaning of the Income Tax Act of October 3, 1913, c. 16, Section II, G. (a), 38 Stat. 114, 166, 172, and were levied in respect of dividends received from a corporation...

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