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Henry Williams
Henry Williams

The Double Identity - November 8, 1965



Actually, in 1965 you could score a meal with a double-decker burger for a buck! If you wanted to go out to dinner, you could eat at Oscar's (a family restaurant chain in California), and for $1 you'd get a double-decker hamburger with French fries, salad, and ice cream for dessert. For only 30 cents more, you could get a complete fried chicken or shrimp dinner (also with fries and salad). Pie was only 35 cents a slice, an ice-cream sundae was 40 cents, and coffee or a soft drink cost 10 cents. By the way, if you wanted to grab a quick bite at a lunch counter, you could get a hot dog and a coke for 49 cents.




The Double Identity - November 8, 1965



The primary object of Section 337 of the Internal Revenue Code was remedial. First, the section intended to eliminate double taxation on the same gain, resulting when a corporation decides to liquidate and thereafter distributes its assets to shareholders themselves subject to taxation. See, United States v. Morton, supra; Pridemark, Inc. v. C. I. R., 345 F.2d 35 (4th Cir. 1965); West Street-Erie Boulevard Corp. v. United States, 411 F.2d 738 (2d Cir. 1969). Second, the section was promulgated to resolve the conflict created by disparate holdings in Commissioner of Internal Revenue v. Court Holding Co., 324 U.S. 331, 65 S. Ct. 707, 89 L. Ed. 981 (1944) and United States v. Cumberland Public Service Co., 338 U.S. 451, 70 S. Ct. 280, 94 L. Ed. 251 (1950), and to eliminate technical distinctions based upon the form of corporate dissolution created by these cases. See, United States v. Morton, supra, 387 F.2d at 444. The thrust of Section 337 is thus to create a rule of exemption which is understandable and easy to apply.


Edward Alexander was born into an Armenian-American family in New York City in 1920. It transpires from his later writings that he was repeatedly harassed (both as a child and later as a diplomat) on account of his ethnic background and developed a firm double identity of being American first, but Armenian above all. He studied music (B.A.) and journalism (M.A.) at Columbia. In World War II he served in the Psychological Warfare Division of the Allied Forces in Europe and worked on Nazi propaganda. After the war he managed Sir Lawrence Olivier's Shakespeare movies in the New World.


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