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SINGER MFG. CO. v. UNITED STATES

Nos. 45537-45539, 45790-45795.

87 F.Supp. 769 (1950)

SINGER MFG. CO. v. UNITED STATES and five other cases.

United States Court of Claims.

Decided January 3, 1950.

Attorney(s) appearing for the Case

Albert L. Hopkins, Chicago, Ill., for plaintiffs. Winthrop, Stimson, Putnam & Roberts, New York City, and Hopkins, Sutter, Halls, DeWolfe & Owen, Chicago, Ill., were on the brief.

J. A. Rees, Washington, D. C., with whom was Assistant Attorney General Theron Lamar Caudle, for defendant. Andrew D. Sharpe, Ellis N. Slack, and Harry Marselli, Special Assistants to the Attorney General, were on the brief.

Before JONES, Chief Judge, and MADDEN, LITTLETON, WHITAKER and HOWELL, Judges.

MADDEN, Judge.

There are two issues in these suits. The first is whether The Singer Manufacturing Company, which sustained a loss in 1926 on the liquidation of its wholly owned subsidiary, Hamel Shoe Machinery Company, could deduct that loss from its 1926 income, in view of additional facts hereinafter recited. The second is whether credit on its American income tax liability may be taken by The Singer Manufacturing Company for payments made, it says on its behalf...

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