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SUN OIL CO. v. C. I. R.

No. 76-2388.

562 F.2d 258 (1977)

SUN OIL COMPANY, Transferee, Sunray DX Oil Company and Subsidiaries, Transferor v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Third Circuit.

Decided September 7, 1977.

As Amended November 29, 1977.

Attorney(s) appearing for the Case

Myron C. Baum, Acting Asst. Atty. Gen., Gilbert E. Andrews, Gary R. Allen, John A. Dudeck, Jr., Attys., Tax Div., Dept. of Justice, Washington, D. C., for appellant.

Thompson, Knight, Simmons & Bullion, Buford P. Berry, J. David Anders, Emily A. Parker, Dallas, Tex., for appellee.

Before SEITZ, Chief Judge, ROSENN, Circuit Judge, and LORD, Chief Judge.

OPINION OF THE COURT

ROSENN, Circuit Judge.

In the quest to obtain capital, to generate business liquidity, or to minimize taxes, private enterprise often resorts to the sale of property and a simultaneous leaseback to the seller. A recurring question in transactions of this sort is whether after the transfer of title to the property some or all of the critical incidents of ownership still remain with the grantor despite his newly designated status as lessee...

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