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BONGIOVANNI v. C. I. R.

No. 172, Docket 72-1597.

470 F.2d 921 (1972)

John P. and Alice BONGIOVANNI, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Second Circuit.

Decided December 11, 1972.

Attorney(s) appearing for the Case

Vincent E. Cerow, New York City, for appellants.

Dennis M. Donohue, Tax Div., Dept. of Justice, Washington, D. C. (Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Paul M. Ginsburg, Tax Div., Dept. of Justice, Washington, D. C., on the brief), for appellee.

Before MOORE, HAYS and MULLIGAN, Circuit Judges.

HAYS, Circuit Judge:

The only point in contention on this appeal is whether Section 357(c) of the Internal Revenue Code of 1954, which imposes a tax on otherwise tax-free Section 351 transfers where the liabilities assumed by the taxpayer's wholly-owned corporation exceed the adjusted basis of property transferred, applies to a cash basis taxpayer's "liabilities" consisting of trade accounts payable.1 The Commissioner

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