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MANASSAS AIRPORT INDUS. PARK, INC. v. C. I. R.

No. 76-2311.

557 F.2d 1113 (1977)

MANASSAS AIRPORT INDUSTRIAL PARK, INC., a Dissolved Corporation, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided June 21, 1977.

Attorney(s) appearing for the Case

Fred R. Tansill, Washington, D.C. (Frederick J. Tansill and Bird & Tansill, Washington, D.C., on brief), for appellant.

Michael J. Roach, Atty., U.S. Dept. of Justice, Washington, D.C. (Myron C. Baum, Acting Asst. Atty. Gen., Gilbert E. Andrews, Michael L. Paup, Attys., U.S. Dept. of Justice, Washington, D.C., on brief), for appellee.

Before WINTER, BUTZNER and HALL, Circuit Judges.

PER CURIAM:

This case presents the question of whether Manassas Airport Industrial Park, Inc. was a collapsible corporation, i.e. one formed or availed of for the construction of property with the objective of subsequent distribution of property to its stockholders and the realization by them of a substantial part of the gain attributable to that property, so that it did not qualify for nonrecognition of the gain realized on the preliquidation sale of its assets under...

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