HOFFMAN MOTORS CORPORATION v. UNITED STATES

No. 60, Docket 72-1418.

473 F.2d 254 (1973)

HOFFMAN MOTORS CORPORATION, 1. (Successor to Hoffman-Porsche Corp.), 2. (Successor to Hoffman Motors Eastern Division, Inc.), 3. (Successor to Hoffman Motor Car Co., Inc.), Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Second Circuit.

Decided January 17, 1973.


Attorney(s) appearing for the Case

Howard L. Mann, Weiss, Bronston, Rosenthal, Heller & Schwartzman, New York City, for plaintiff-appellant.

Joel B. Harris, Asst. U.S. Atty. (Whitney North Seymour, Jr., U.S. Atty., S. D. New York, Daniel H. Murphy II, Asst. U.S. Atty., of counsel), for defendant-appellee.

Before MANSFIELD, OAKES and TIMBERS, Circuit Judges.


OAKES, Circuit Judge:

Appellant taxpayer is the successor to a family of foreign car corporations, consisting of a parent, Hoffman Motor Car Co., Inc. (hereinafter "Hoffman Motor") and several wholly owned subsidiaries—Hoffman-Porsche Corp. (hereinafter "Hoffman-Porsche"); Hoffman Motors Eastern Division, Inc. (hereinafter "Eastern"); and Hoffman of California, Inc., a/k/a Hoffman Western Division, Inc. (hereinafter "Western"). The appeal relates to automobile...

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