Felin v. Kyle

MARIS, District Judge.

These are suits against the former acting collector of internal revenue for the First collection district of Pennsylvania brought by two residents of the district to recover income taxes alleged to have been erroneously collected for the calendar year 1932. The cases were tried together and will be disposed of in one opinion. From the evidence I make the following special findings of fact:

*557Prior to 1928 the plaintiffs owned stock in Charles F. Felin & Co., which stock pursuant to a reorganization was exchanged in that year lor preferred stock and ten-year 6% per cent,…