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ANASTASATO v. C.I.R.

Nos. 85-5728, 86-5143.

794 F.2d 884 (1986)

Pano ANASTASATO and Janice Anastasato v. COMMISSIONER OF INTERNAL REVENUE. Appeal of Pano ANASTASATO, Appellant in 85-5728. Appeal of Janice ANASTASATO, Appellant in 86-5143.

United States Court of Appeals, Third Circuit.

Decided July 8, 1986.

Attorney(s) appearing for the Case

Alan H. Levine (argued), Frankfurt, Garbus, Klein & Selz, P.C., New York City, Edward H. Rosenthal, of counsel, for appellants.

Kathryn E. Rooklidge (argued), Michael L. Paup, Charles E. Brookhart, Roger M. Olsen, Acting Asst. Atty. Gen., Glenn L. Archer, Jr., Asst. Atty. Gen., Department of Justice, Tax Division, George M. Sellinger, Washington, D.C., for appellee.

Before SEITZ, HUNTER, and MANSMANN, Circuit Judges.

OPINION OF THE COURT

HUNTER, Circuit Judge.

Pano Anastasato, the taxpayer, has been involved in the travel business since 1954. In 1960, he established his own travel agency, Panmarc, Inc. ("Panmarc"), and a tour operation business, Wholesale Tours International ("WTI"). During the years 1974 through 1976, both companies were wholly owned by the taxpayer.

Panmarc purchased tickets for WTI's customers. Panmarc was licensed by the International Air...

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