INTERNATIONAL FLAVORS & FRAGRANCES INC., Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
United States Court of Appeals, Second Circuit.https://leagle.com/images/logo.png
Argued September 23, 1975.
Decided October 8, 1975.
Attorney(s) appearing for the Case
George Rowe, Jr., New York City (Fulton, Walter & Duncombe, Michael J. Gaynor, New York City, on the brief), for petitioner-appellant.
Robert A. Bernstein, Atty., Tax Div., Dept. of Justice, Washington, D. C. (Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews and Michael L. Paup, Attys., Washington, D. C., on the brief), for respondent-appellee.
Before FRIENDLY, HAYS and FEINBERG, Circuit Judges.
United States Court of Appeals, Second Circuit.
FEINBERG, Circuit Judge:
This appeal from a decision of the Tax Court, 62 T.C. 232 (1974), finding a deficiency of $73,715 in the 1967 tax payment of appellant International Flavors & Fragrances Inc. (IFF), comes to us in a peculiar posture. Appellee Commissioner of Internal Revenue persuaded a majority of the Tax Court on a theory from which he now withdraws. Instead appellee asks us to affirm on an alternative theory based on...
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