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FORT HAMILTON MANOR, INC. v. C. I. R.

Nos. 260, 261, Dockets 34484, 34485.

445 F.2d 879 (1971)

FORT HAMILTON MANOR, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. DAYTON DEVELOPMENT FORT HAMILTON CORP., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided July 1, 1971.

Attorney(s) appearing for the Case

Stuart E. Seigel, Washington, D. C. (Cohen & Uretz, Norman L. Schwartz, Washington, D. C., of counsel), for petitioners-appellants.

John A. Townsend, Attorney, Tax Div., Dept. of Justice, Washington, D. C. (Johnnie M. Walters, Asst. Atty. Gen., Dept. of Justice, Meyer, Rothwacks and Grant W. Wiprud, Attys., Tax Div., Dept. of Justice, Washington, D. C., of counsel), for respondent-appellee.

Before WATERMAN, MOORE and FEINBERG, Circuit Judges.

MOORE, Circuit Judge:

Petitioners Fort Hamilton Manor, Inc. (Fort Hamilton) and Dayton Development Fort Hamilton Corp. (Dayton Development) appeal from judgments of the Tax Court wherein it was adjudged that there were deficiencies in income taxes due from Fort Hamilton for the fiscal years ending May 31, 1961 and May 31, 1962 of $362,379 and $12,705, respectively and from Dayton Development for the fiscal year ending November 30, 1961 of $159,047.

Fort Hamilton...

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