ANDREW CRISPO GALLERY, INC. v. C.I.R.

No. 668, Docket 95-4064.

86 F.3d 42 (1996)

ANDREW CRISPO GALLERY, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided June 13, 1996.


Attorney(s) appearing for the Case

Walter J. Rockler, Washington, D.C. (Richard J. Wertheimer, Julius M. Greisman, Arnold & Porter, Washington, D.C., of counsel), for Petitioner-Appellant.

Kenneth W. Rosenberg, U.S. Department of Justice, Tax Division, Washington, D.C. (Loretta C. Argrett, Assistant Attorney General, Gary R. Allen, Gilbert S. Rothenberg, U.S. Department of Justice, Tax Division, Washington, D.C. Washington, D.C., of counsel), for Respondent-Appellee.

Before VAN GRAAFEILAND, MESKILL and WINTER, Circuit Judges.


VAN GRAAFEILAND, Circuit Judge:

Andrew Crispo Gallery, Inc. ("the Gallery") appeals from a decision of the United States Tax Court (Cohen, J.) holding that the Gallery was not entitled to use the installment method of reporting income to defer recognition of profits derived from a sale of paintings seized and sold at auction by the Internal Revenue Service ("IRS"). This is the second time the Gallery has been before us seeking relief from adverse decisions of the...

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