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SENATE REALTY CORPORATION v. C. I. R.

No. 376, Docket 74-1861.

511 F.2d 929 (1975)

SENATE REALTY CORPORATION, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided February 20, 1975.

Attorney(s) appearing for the Case

M. Lauck Walton, New York City (Donovan, Leisure, Newton & Irvine, John C. Baity, New York City, of counsel), for petitioner-appellant.

Robert G. Burt, Atty., Tax Div., Dept. of Justice, Washington, D. C. (Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, Bennet N. Hollander, Attys., Tax Div., Dept. of Justice, Washington, D. C., of counsel), for respondent-appellee.

Before WATERMAN, HAYS and MULLIGAN, Circuit Judges.

MULLIGAN, Circuit Judge:

Senate Realty Corporation (Senate), a New York corporation, received a statutory notice of deficiency dated February 15, 1966 from the Commissioner of Internal Revenue (IRS), which asserted deficiencies in the taxpayer's income taxes for the taxable year 1959 in the amount of $234,825.50 plus a penalty in the sum of $117,412.75. Redetermination proceedings in the Tax Court were commenced by an attorney then representing Senate on March 14...

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