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LIANT RECORD, INC. v. COMMISSIONER

Docket Nos. 72955, 83431-83433.

22 T.C.M. 203 (1963)

T.C. Memo. 1963-53

Liant Record, Inc. v. Commissioner. William I. Alpert and Paula G. Alpert v. Commissioner. Abraham Alpert and Sarah Alpert v. Commissioner. Jack L. Alpert v. Commissioner.

United States Tax Court.

Filed February 21, 1963.

Attorney(s) appearing for the Case

Bernard J. Long, Esq., and A. J. Schiffer, Esq., 570 Seventh Ave., New York 18, N. Y. for the petitioners. Gerald Robinson, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

ATKINS, Judge:

This proceeding is before us on mandate from the United States Court of Appeals for the Second Circuit, issued pursuant to that court's opinion in Liant Record, Inc. v. Commissioner [62-1 USTC ¶ 9494], 303 F.2d 326.

In Liant Record, Inc. [Dec. 24,807], 36 T.C. 224, we held that three residential apartment buildings...

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