Court of Appeals for the D.C. Circuit January 14, 1935, No. 6240 (Detroit Gear & Machine Co. v. Helvering)

GRONER, Associate Justice.

Petitioner is a Michigan corporation whose principal business is the manufacture and sale of automobile parts and transmissions.

Some time prior to January 1, 1927, its general manager procured a license agreement with the owner of a patent, and in 1926 he and his associates caused two new corporations to be organized under the laws of Michigan for the purpose of