ESTATE of Aaron LEVINE, Deceased, Harvey Levine, Executor and Anna Levine, Surviving Wife, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
United States Court of Appeals, Second Circuit.https://leagle.com/images/logo.png
Argued June 6, 1980.
Decided July 10, 1980.
Attorney(s) appearing for the Case
L. William Fishman, New York City (Rosen & Reade, Martin Rosen and Barry L. Gardiner, New York City, of counsel), for petitioners-appellants.
Richard D. Buik, Tax Div., Dept. of Justice, Washington, D. C. (M. Carr Ferguson, Asst. Atty. Gen., Tax Div., Dept. of Justice, Gilbert E. Andrews, and Jonathan S. Cohen, Washington, D. C., of counsel), for respondent-appellee.
Before FRIENDLY, KAUFMAN and TIMBERS, Circuit Judges.
United States Court of Appeals, Second Circuit.
FRIENDLY, Circuit Judge:
The estate of Aaron Levine and his widow Anna1 appeal from a part of a decision of the Tax Court, 72 T.C. 68 (1979), which found a deficiency of $130,428.42 in Aaron Levine's 1970 income tax. The deficiency resulted from a determination by the Commissioner that the taxpayer had realized gain upon his gift, on January 1, 1970, of income producing property consisting of land and a building at 20-24 Vesey Street in...
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