MOTION PICTURE CAPITAL CORP. v. COMMISSIONER OF INT. REV.

Nos. 95, 96.

80 F.2d 872 (1936)

MOTION PICTURE CAPITAL CORPORATION v. COMMISSIONER OF INTERNAL REVENUE. INVESTORS EQUITY CO., Inc., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

January 6, 1936.


Attorney(s) appearing for the Case

Bernhard Knollenberg and Harry J. Rudick, both of New York City (Lord, Day & Lord, of New York City, of counsel), for appellants.

Frank J. Wideman, Asst. Atty. Gen., and Sewall Key and John MacC. Hudson, Sp. Assts. to the Atty. Gen., for respondent.

Before MANTON, AUGUSTUS N. HAND, and CHASE, Circuit Judges.


CHASE, Circuit Judge.

As Investors Equity Company, Inc., does not dispute its liability for the deficiency as transferee provided any tax is due, we shall discuss the merits as though Motion Picture Capital Corporation were alone the petitioner.

It was organized in 1923 under the laws of Delaware. The expenses of its organization were $49,464.83, and some time later it paid $10,440.50 in addition for expenses incurred in increasing its capital. These payments...

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