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COMMISSIONER OF INTERNAL REV. v. PIEDRAS NEGRAS B. CO.

No. 10035.

127 F.2d 260 (1942)

COMMISSIONER OF INTERNAL REVENUE v. PIEDRAS NEGRAS BROADCASTING CO.

Circuit Court of Appeals, Fifth Circuit.

April 3, 1942.

Attorney(s) appearing for the Case

Bernard Chertcoff, Sewall Key, and J. Louis Monarch, Sp. Assts. to the Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Vernon F. Weekley, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for petitioner.

Robert Ash, of Washington, D. C., for respondent.

Before HUTCHESON, HOLMES, and McCORD, Circuit Judges.

HOLMES, Circuit Judge.

The respondent is a corporation organized under the laws of the State of Coahuila, Republic of Mexico, with its principal office and place of business at Piedras Negras, Mexico. Its business is the operation of a radio broadcasting station located at Piedras Negras, just across the Rio Grande from Eagle Pass, Texas. The decisive question presented by this petition for review is whether the respondent, from the operation of its business in 1936...

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