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INVESTERS DIVERSIFIED SERVICES, INC. v. C.I.R.

No. 17294.

325 F.2d 341 (1963)

INVESTERS DIVERSIFIED SERVICES, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

December 13, 1963.

Attorney(s) appearing for the Case

Joseph A. Maun, St. Paul, Minn., and Kenneth M. Anderson, Minneapolis, Minn., made argument for petitioner and were on the brief with counsel, Maun, Hazel, Green, Hayes, Simon & Aretz, St. Paul, Minn., and Cant, Haverstock, Beardsley, Gray & Plant, Minneapolis, Minn.

Harry Marselli, Atty., Tax Division, Dept. of Justice, Washington, D. C., made argument for respondent and Louis F. Oberdorfer, Asst. Atty. Gen., Meyer Rothwacks, Gilbert E. Andrews and Crombie J. D. Garrett, Attys., Tax Division, Dept. of Justice, Washington, D. C., were on the brief.

Before VOGEL, MATTHES and MEHAFFY, Circuit Judges.

MEHAFFY, Circuit Judge.

Investors Diversified Services, Inc. (hereinafter called "Petitioner") has petitioned us to review a decision of the Tax Court affirming the disallowance of income tax deductions and a claimed refund by the Commissioner of Internal Revenue Service. See 39 T.C. 25.

During the years in issue, 1954 and 1955, Petitioner engaged, inter alia, in the sale of loans secured by mortgages to wholly owned subsidiary corporations and non...

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