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COMMISSIONER v. BOLLINGER

No. 86-1672.

485 U.S. 340 (1988)

COMMISSIONER OF INTERNAL REVENUE v. BOLLINGER ET AL.

Supreme Court of United States.

Decided March 22, 1988

Attorney(s) appearing for the Case

Alan I. Horowitz argued the cause for petitioner. With him on the briefs were Solicitor General Fried, Acting Assistant Attorney General Durney, Deputy Solicitor General Lauber, Richard Farber, and Teresa E. McLaughlin.

Charles R. Hembree argued the cause for respondents. With him on the brief was Philip E. Wilson.*

JUSTICE SCALIA delivered the opinion of the Court.

Petitioner, the Commissioner of Internal Revenue, challenges a decision by the United States Court of Appeals for the Sixth Circuit holding that a corporation which held record title to real property as agent for the corporation's shareholders was not the owner of the property for purposes of federal income taxation. 807 F.2d 65 (1986). We granted certiorari, 482 U.S. 913 (1987),...

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