Huyler's v. Commissioner of Internal Revenue

KNOCH, Circuit Judge.

Petitioner, Huyler’s, was organized in New York in 1881 with broad powers. According to the Restated Certificate of Incorporation filed November 1,1950, the purposes for which the corporation was formed included the following:

“(d) To buy, hold, own, manufacture, produce, sell, exchange, import, export, and otherwise hold and dispose of, either as principal or agent, and upon commission or otherwise, all kinds of personal property whatsoever, except bills of exchange, without limit as to amount and without restriction as to location;

“(e) To apply for, purchase, or…