EISENBERG v. C.I.R.

Docket No. 97-4331.

155 F.3d 50 (1998)

Irene EISENBERG, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided August 18, 1998.


Attorney(s) appearing for the Case

Martin A. Stoll, New York, New York, for Petitioner-Appellant.

David I. Pincus, Tax Division, Department of Justice, Washington D.C., (Loretta C. Argrett, Assistant Att. Gen., Tamara W. Ashford, Attorney), for Respondent-Appellee.

Before: WINTER, Chief Judge, JACOBS, Circuit Judge, and CARMAN, Chief Judge.


CARMAN, Chief Judge:

BACKGROUND2

Appellant, Irene Eisenberg, owned all 1,000 shares of the issued and outstanding common stock of Avenue N Realty Corporation (the Corporation), its only class of stock. The Corporation, a C corporation3 for tax purposes during 1991, 1992 and 1993, the years in issue, was organized under the laws of the State of New York. The...

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