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HELVERING v. PRODUCERS CORP.

No. 600.

303 U.S. 376 (1938)

58 S.Ct. 623

82 L.Ed. 907

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. MOUNTAIN PRODUCERS CORPORATION.

Supreme Court of United States.

Decided March 7, 1938.

Attorney(s) appearing for the Case

Assistant Solicitor General Bell, with whom Solicitor General Reed, Assistant Attorney General Morris, and Messrs. Sewall Key, Maurice J. Mahoney, Warner W. Gardner, and Edward J. Ennis were on the brief, for petitioner.

Mr. Harold D. Roberts, with whom Mr. Randolph E. Paul was on the brief, for respondent.

MR. CHIEF JUSTICE HUGHES delivered the opinion of the Court.

Respondent, Mountain Producers Corporation, owned all the capital stock of the Wyoming Associated Oil Corporation and filed a consolidated income tax return for the year 1925. Two distinct questions are involved with respect to the taxable income of the above-mentioned affiliate. These are (1) as to the amount of the gross income of the affiliate for the purpose of the statutory allowance for depletion in...

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