MADISON SQUARE GARDEN CORPORATION (formerly Graham-Paige Corporation), Petitioner-Appellant/Appellee,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant/Appellee.
United States Court of Appeals, Second Circuit.https://leagle.com/images/logo.png
Argued May 23, 1974.
Decided July 30, 1974.
Attorney(s) appearing for the Case
David G. Sacks, New York City (Simpson, Thacher & Bartlett, Michael H. Simonson, Margaret Ann Murdich, New York City, of counsel), for petitioner-appellant/appellee.
Carolyn R. Just, Atty. Tax Div. (Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Ernest J. Brown, Attys., Tax Div., Dept. of Justice, Washington, D.C., of counsel), for respondent-appellant/appellee.
Before SMITH and TIMBERS, Circuit Judges, and TYLER, District Judge.
United States Court of Appeals, Second Circuit.
J. JOSEPH SMITH, Circuit Judge:
These are cross-appeals from a decision by the Tax Court, 58 T.C. 619 (1972), Irene F. Scott, Judge, holding (1) that the taxpayer, Madison Square Garden Corporation (MSG), was entitled under 26 U.S.C. § 334(b)(2) to a stepped-up basis for assets acquired through a merger-liquidation of a controlled corporation, but (2) that it was limited in this step-up...
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