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J. C. CORNILLIE CO. v. UNITED STATES

Civ. A. No. 25676.

298 F.Supp. 887 (1968)

J. C. CORNILLIE CO., Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court E. D. Michigan, S. D.

November 7, 1968.

Attorney(s) appearing for the Case

J. Bruce Donaldson and David P. Ruwart, Raymond, Chirco, Fletcher, Donaldson & Ruwart, Detroit, Mich., for plaintiff.

Arthur L. Stern, III, U. S. Dept. of Justice, Washington, D. C., for defendant.

OPINION

TALBOT SMITH, District Judge.

This action is a suit for refund by plaintiff, J. C. Cornillie Company, against the United States of America, to recover income tax in the amount of $15,600.00 plus statutory interest which was assessed against it for the fiscal years ending March 31, 1960 and 1961. (Stip. ¶ 2) It is a case requiring much analysis in detail since the problem is one of differentiating form from substance. It stems, as we later point...

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