REEF CORPORATION v. C. I. R.

No. 22836.

368 F.2d 125 (1966)

REEF CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. REEF CORPORATION, Respondent.

United States Court of Appeals Fifth Circuit.

Rehearing Denied December 15, 1966.


Attorney(s) appearing for the Case

Homer L. Bruce, William C. Griffith, Robert J. Piro, Houston, Tex., for petitioners. Baker, Botts, Shepherd & Coates, Houston, Tex., of counsel.

Mitchell Rogovin, Chief Counsel, I. R. S., John B. Jones, Jr., Act. Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Hu S. Vandervort, Jr., Atty., I. R. S., Richard M. Roberts, Act. Asst. Atty. Gen., Harry Baum, Fred R. Becker, Attys., Dept. of Justice, Washington, D. C., for appellee.

Before RIVES and BELL, Circuit Judges and FULTON, District Judge.


BELL, Circuit Judge.

This appeal is from a decision of the Tax Court reported as Reef Corporation v. Commissioner, T.C. Memo. 1965-72 and CCH Dec. 27309(M). It involves income taxes. Reef Corporation appeals from the disallowance of a stepped-up basis of depreciation, and of interest on corporate indebtedness. The Commissioner, by way of a cross-appeal, contends that the Tax Court erred in not holding that the transaction which...

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