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UNITED STATES v. HILTON HOTELS

No. 528.

397 U.S. 580 (1970)

90 S.Ct. 1307

25 L.Ed.2d 585

UNITED STATES v. HILTON HOTELS CORP.

Supreme Court of United States.

Decided April 20, 1970

Attorney(s) appearing for the Case

Assistant Attorney General Walters argued the cause for the United States. With him on the brief were Solicitor General Griswold, Matthew J. Zinn, Gilbert E. Andrews, and Stuart A. Smith.

Milton A. Levenfeld argued the cause for respondent. With him on the brief were Burton W. Kanter and Richard M. Kates.

MR. JUSTICE MARSHALL delivered the opinion of the Court.

This is the companion case to Woodward v. Commissioner, ante, p. 572, and presents a similar question involving the tax treatment of appraisal litigation expenses.

In 1953 taxpayer Hilton Hotels Corporation, which owned close to 90% of the common shares of the Hotel Waldorf-Astoria Corporation, determined to merge the two companies. Hilton retained a consulting firm to prepare a merger...

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