American Smelting & Refining Co. v. United States

FORMAN, District Judge.

This is an action by the plaintiff, American Smelting and Refining Company, based upon the contention that it is entitled to a deduction in its return of income for the year 1925, and involving a claim for refund to the extent of the alleged deduction.

Plaintiff owned and controlled the American Smelting Securities Company up to its dissolution on January 31, 1923 by virtue of its ownership of all common stock. In addition, there were outstanding issues of Six Per Cent. Cumulative Preferred Stock, Series A, and Five Per *335Cent. Cumulative Preferred Stock, Series B, both of…