Werner ABEGG, Appellee,
v.
COMMISSIONER OF INTERNAL REVENUE, Appellant.
CRESTA CORPORATION, S.A., Transferee, Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Appellee.
United States Court of Appeals, Second Circuit.https://leagle.com/images/logo.png
Argued May 28, 1970.
Decided July 14, 1970.
Attorney(s) appearing for the Case
Emilio A. Dominianni, New York City (John E. McDermott, Jr., Michael Keating and Coudert Brothers, New York City, of counsel), for Werner Abegg and Cresta Corporation.
Paul M. Ginsburg, Atty., Department of Justice, Washington, D. C. (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson and Thomas L. Stapleton, Attys., Dept. of Justice, Washington, D. C., of counsel), for Commissioner of Internal Revenue.
Before WATERMAN, FRIENDLY and HAYS, Circuit Judges.
United States Court of Appeals, Second Circuit.
FRIENDLY, Circuit Judge:
These two appeals from a decision of the Tax Court, 50 T.C. 145, one by the taxpayer and the other by the Commissioner, concern a series of transactions in which Werner Abegg, a Swiss citizen, liquidated one wholly-owned personal holding company and transferred all its assets, plus other securities in substantial amount, to another personal holding company. Although the appeals relate to different tax years...
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