SISTO FINANCIAL CORPORATION v. COMMISSIONER OF INT. REV.

No. 214.

149 F.2d 268 (1945)

SISTO FINANCIAL CORPORATION v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

April 27, 1945.


Attorney(s) appearing for the Case

Robert C. Vincent and Charles J. Colgan, both of New York City, for petitioner.

Bernard Chertcoff, of Washington, D. C., Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Helen R. Carloss, Sp. Assts. to Atty. Gen. (Willkie, Owen, Otis, Farr & Gallagher, of New York City, of counsel), for respondent.

Before L. HAND and CHASE, Circuit Judges.


L. HAND, Circuit Judge.

This appeal is a sequel to our decision upon an appeal of the Commissioner from an order of the Tax Court, expunging an assessment for deficiency in the taxpayer's income tax for the year 1936. Commissioner of Internal Revenue v. Sisto Financial Corporation, 139 F.2d 253. The only question then left open was the value of 159,899 shares of the stock of the Barium Stainless Steel Corporation, received by the...

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