TELEVISION INDUSTRIES, INC. v. C. I. R.

No. 10, Docket 26144.

284 F.2d 322 (1960)

TELEVISION INDUSTRIES, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals Second Circuit.

Decided November 14, 1960.


Attorney(s) appearing for the Case

Henry W. de Kosmian, of Cravath, Swaine & Moore, New York City (George S. Parlin, Jr. and Edward P. Tolley, Jr., of Cravath, Swaine & Moore, New York City, on the brief), for petitioner.

L. W. Post, of the Department of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Meyer Rothwacks and Robert N. Anderson, Attorneys, of Department of Justice, Washington, D. C., on the brief), for respondent.

Before CLARK, MAGRUDER and FRIENDLY, Circuit Judges.


FRIENDLY, Circuit Judge.

This is a petition by a taxpayer to review a decision of the Tax Court, 32 T.C. 1297, finding petitioner liable as transferee for a deficiency of $77,199.53, together with interest, in the income tax of National Phoenix Industries, Inc., hereafter "Phoenix." This finding stems from a conclusion that $1,026,285 received by Phoenix from Nedick's, Inc. on November 15, 1951, and not reported as income, was taxable...

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