Seattle Hardware Co. v. Squire

LEAVY, District Judge.

This is an action brought under section 1340 of 28 U.S.C.A., as qualified by section 3772 of the Internal Revenue Code, as amended, 26 U.S.C.A. § 3772, for the recovery of income and excess profits taxes, alleged to have been erroneously and illegally assessed and collected for the fiscal years 1941 to 1945, inclusive, excepting the year 1942.

The question presented here is whether the corporate entity of the Occident Trust Company should be recognized in connection with the record ownership of certain real property prior to the time such property was formally transferred…