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ROCKWELL SPRING & AXLE COMPANY v. GRANGER

Civ. A. No. 10138.

140 F.Supp. 390 (1956)

ROCKWELL SPRING & AXLE COMPANY, successor by merger to Standard Steel Spring Company, v. Stanley GRANGER, Collector of Internal Revenue for the 23rd Collection District of Pennsylvania.

United States District Court W. D. Pennsylvania.

March 29, 1956.

Attorney(s) appearing for the Case

Thomas J. McManus, W. A. Seifert (of Reed, Smith, Shaw & McClay), Pittsburgh, Pa., for plaintiff.

D. Malcolm Anderson, Jr., U. S. Atty., Pittsburgh, Pa., Arthur Biggins, Sp. Atty., Kenneth Ray, Sp. Atty., Department of Justice, Washington, D. C., for defendant.

MARSH, District Judge.

The problem here centers on the distribution in December of 1946 of $147,000 by Muehlhausen Spring Corporation (hereinafter called "Muehlhausen"), a wholly-owned subsidiary of its parent, Standard Steel Spring Company1 (hereinafter called "Standard"), in redemption of all of Muehlhausen's outstanding 6% cumulative preferred stock. Standard contends that the transfer constituted a partial liquidation of its subsidiary...

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