UNITED STATES STEEL CORPORATION, Appellant-Cross-Appellee,
v.
COMMISSIONER OF INTERNAL REVENUE, Appellee-Cross-Appellant.
United States Court of Appeals, Second Circuit.https://leagle.com/images/logo.png
Argued November 29, 1979.
Decided March 12, 1980.
Attorney(s) appearing for the Case
Robert T. Duffy, and Gilbert S. Rothenberg, Washington, D. C. (M. Carr Ferguson, Asst. Atty. Gen., William A. Friedlander, Gary R. Allen, and R. Bruce Johnson, Attys., Tax Div., Dept. of Justice, Washington, D. C., of counsel), for the Commissioner, appellee-cross-appellant.
Haliburton Fales, II, and David Sachs, New York City (White & Case, New York City, A. Chauncey Newlin, Allan L. Gropper, and Michael L. Lieberman, New York City, of counsel), for United States Steel Corp., appellant-cross-appellee.
Before LUMBARD, MESKILL and NEWMAN, Circuit Judges.
United States Court of Appeals, Second Circuit.
LUMBARD, Circuit Judge:
This consolidated appeal1 from two decisions of the Tax Court, Quealy, J., arises out of the development by United States Steel Corporation ("Steel") of newly discovered Venezuelan iron mines in the 1950's, and the financial arrangements resulting from the creation of two Steel subsidiaries to mine and transport ore. Two distinct questions of tax law are presented: first, what kind of evidence is sufficient for...
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