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HUMMEL & DOWNING COMPANY v. COMMISSIONER

Docket No. 26283.

19 T.C. 61 (1952)

HUMMEL & DOWNING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 24, 1952.

Attorney(s) appearing for the Case

Elden McFarland, Esq., for the petitioner.

Arthur B. White, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The petitioner was a wholly owned subsidiary of Corn Products Refining Company at all times material hereto prior to December 1, 1941, when it was purchased by Cornell Wood Products Company.

The petitioner had been engaged for many years in manufacturing and selling paper board containers and it manufactured two types of paper board which it used in the construction of the containers. One type of paper board which...

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