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CASALINA CORP. v. C. I. R.

No. 74-1973.

511 F.2d 1162 (1975)

CASALINA CORPORATION, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided March 17, 1975.

Attorney(s) appearing for the Case

Leon Bizar, New York City, for appellant.

Robert A. Bernstein, Washington, D. C. (Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, and Bennett N. Hollander, Attys., Tax Div., U. S. Dept. of Justice, on brief), for appellee.

Before WINTER, CRAVEN and RUSSELL, Circuit Judges.

PER CURIAM:

The Tax Court denied (1) taxpayer's claim for nonrecognition of its condemnation claims under Section 1033 of the Internal Revenue Code of 1954; (2) taxpayer's allocation of part of its legal fees incurred in the condemnation proceedings to interest received on the awards and the consequent deduction as a current expense of the fees so allocated; (3) taxpayer's claim that the interest received on the awards might be allocated to pre-judgment years; and...

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