| OCR Text |
Show levied of upon and perfumes. plaint was defendent's granted, The said, Inc., Revenue Act Gince method used by Commissioner the the was if the the sale dismiss the com that plaintiff course, be texed "is under LL.T, The net a manu-+ parsirreph ‘eee 3 decision rests on the finding was a sham, and sale of the Browning corporations the Cempany was that since not the the Arms Company to J. & B. &S. Browning faith, we shall take the Liber cy Of quoting somewhat large from the in capital $2,000, which zood at opinion: "Laboratories! constituted ty stock plaintiff of Piver of 1932." contends that Mw. the manufacturer, of 605 motion. to on it, mey not, plaintiff claimed that it the not the plaintiff properly, facturer, of from The Laboratories, court collected the the was collection in that of dividends amount, wos on the effected by some specles of legerdemain which the witnesses were unable to explain at the trial and which avoided even the endorsement of dividend checks, The cheeks were not produced and the court believes the trensnetion was nothing more than a book entry of the dividend resolution on the plaintiff's books and maybe a signing of receipts at the convenience of the stockholders. Laborator{er end the pleintiff have the same officers and directors end the same stockholders, At the time of formation, all the enuipment and stoek was turned carry the of $6,416 furnish over to it by the ae stated, Laboratories! then on hand plaintiff, The books machinery, tools and eculpment at a value and the merchandise at 218, 653.97. To the alleged consideration for their plaintiff eleaims 1t leaned Laboratories It was merely a book entry, not so much transfer 924,000. as a note having been given for it. The entry into the operations of ite cpg ytd by Laboratories worked not the slightest change in the ouarters of the plaintiff, Its name was not on the nall board nor on the outside |