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CINCINNATI TRANSIT, INC. v. COMMISSIONER OF INTERNAL REVENUE

No. 71-1501.

455 F.2d 220 (1972)

CINCINNATI TRANSIT, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

February 16, 1972.

Attorney(s) appearing for the Case

Robert S. Brown, Cincinnati, Ohio, for petitioner-appellant; J. W. Brown, Benjamin Gettler, Brown & Gettler, Cincinnati, Ohio, on brief.

Jane M. Edmisten, Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee; Fred B. Ugast, Acting Asst. Atty. Gen., Meyer Rothwacks, Paul M. Ginsburg, Attys., Tax Div., Dept. of Justice, Washington, D. C., on brief.

Before EDWARDS and PECK, Circuit Judges, and McALLISTER, Senior Circuit Judge.

PER CURIAM.

The Cincinnati Transit Company filed a timely petition for redetermination of a deficiency proposed by the Commissioner, and it was joined in the petition by Cincinnati Transit, Inc. Cincinnati Transit, Inc. was formed as a wholly-owned subsidiary of Cincinnati Transit Company, and both currently have assets and are doing business in Ohio. Pursuant to an agreement required by a Cincinnati ordinance, all obligations and liabilities of the Transit Company...

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