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LESLIE SALT CO. v. UNITED STATES

No. 30871.

110 F.Supp. 680 (1953)

LESLIE SALT CO. v. UNITED STATES.

United States District Court N. D. California, S. D.

January 29, 1953.

Attorney(s) appearing for the Case

Walter C. Fox, Jr., and Chickering & Gregory, San Francisco, Cal., for plaintiff.

Chauncey Tramutolo, U. S. Atty., and Charles Elmer Collett, Asst. U. S. Atty., San Francisco, Cal., Charles S. Lyon, Asst. Atty. Gen., Andrew D. Sharpe and F. A. Michels, Sp. Assts. to Atty. Gen., for defendant.

GOODMAN, District Judge.

26 U.S.C. § 18011 imposes a tax of 11 cents on each $100 of face value, inter alia, upon all "debentures" issued by any corporation.

Plaintiff corporation owed large sums of money to certain banks. In order to fund these loans and to obtain needed working capital, it borrowed $1,000,000 from Pacific Mutual Life Insurance Company and $3,000,000 from Mutual...

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