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RESORTS INTERNATIONAL, INC. v. C. I. R.

No. 74-1955.

511 F.2d 107 (1975)

RESORTS INTERNATIONAL, INC., Petitioner-Appellant-Cross-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee-Cross-Appellant.

United States Court of Appeals, Fifth Circuit.

April 14, 1975.

Attorney(s) appearing for the Case

John K. Antholis, New York City, for petitioner-appellant-cross-appellee.

Scott P. Crampton, Asst. Atty. Gen., Dept. of Justice, Tax Div., Meade Whitaker, Chief Counsel, I.R.S., Gilbert E. Andrews, Acting Chief, Appellate Sec., Richard Farber, Leonard J. Henzke, Jr., Attys., Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee-cross-appellant.

Before TUTTLE, COLEMAN and SIMPSON, Circuit Judges:

TUTTLE, Circuit Judge.

This tax case involves four separate sets of transactions entered into by the taxpayer, Resorts International, during the tax years 1962 through 1965. The Commissioner assessed deficiencies totalling $124,924 for these years, in response to which the taxpayer filed a petition in the Tax Court for a redetermination of the deficiency. The Tax Court upheld three of the four deficiencies assessed by the Commissioner. 60 T.C. 778<...

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