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ATLANTIC PROPERTIES, INC. v. C.I.R.

No. 74-1439.

519 F.2d 1233 (1975)

ATLANTIC PROPERTIES, INC., Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, First Circuit.

Decided August 11, 1975.

Attorney(s) appearing for the Case

David H. Halpert, Boston, Mass., with whom Gadsby & Hannah, Boston, Mass., was on brief for appellant.

Louis A. Bradbury, Atty., Tax Div., Dept. of Justice, with whom Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews and Richard Farber, Attys., Tax Div., Dept. of Justice, were on brief, for appellee.

Before COFFIN, Chief Judge, McENTEE and CAMPBELL, Circuit Judges.

COFFIN, Chief Judge.

This is an appeal from a decision of the United States Tax Court, 62 T.C. 73 (1974). We affirm. Since that court's opinion contains a thorough presentation of the facts and discussion of the law, we confine ourselves only to such a summary as will make the issue intelligible.

The challenged holding is that taxpayer, a Massachusetts corporation engaged in the management and rental of some twenty aging industrial...

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