Ticket Off. Equip. Co., Inc. v. Comm'r of Internal Revenue, 213 F.2d 318 (2d Cir. 1954). · Go Syfert
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Ticket Off. Equip. Co., Inc. v. Comm'r of Internal Revenue, 213 F.2d 318 (2d Cir. 1954). Cases Citing This Book View Copy Cite
33 citation events across 6 distinct courts.
Strongest positive: Equity Planning Corp. v. Commissioner (tax, 1983-01-31)
Treatment trajectory · 1954 → 2026 · click a year to view as-of
1954 1990 2026
Top citers, strongest first. 1 distinct citer. How cited ↗
discussed Cited "see" Equity Planning Corp. v. Commissioner
Tax Ct. · 1983 · signal: see · confidence high
See Ticket Office Equipment Co. v. Commissioner, 20 T.C. 272 , 276 , 278 (1953) , affd. per curiam 213 F.2d 318 (2d Cir. 1954) . 18 Secondly, we believe that petitioner's suit for performance under the lease and specific performance by the guarantors suggest that the apartment project was not so heavily encumbered that it could not become a viable venture upon completion.
Retrieving the full opinion text from the archive…
Ticket Office Equipment Company, Inc.
v.
Commissioner of Internal Revenue
22959_1.
Court of Appeals for the Second Circuit.
Jun 4, 1954.
213 F.2d 318
Published

213 F.2d 318

54-2 USTC P 9440

TICKET OFFICE EQUIPMENT COMPANY, Inc., Petitioner,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.

No. 248, Docket 22959.

United States Court of Appeals
Second Circuit.

Argued May 13, 1954.
Decided June 4, 1954.

Richard W. Wilson, New York City, for petitioner.

H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack and Morton K. Rothschild, Sp. Assts. to Atty. Gen., for respondent.

Before CHASE, Chief Judge, and HINCKS and HARLAN, Circuit Judges.

PER CURIAM.

1

Such evidence as there is to indicate that Mrs. Ruscher, as a partner of her husband, owned any part of the assets transferred to the petitioner in exchange for its stock is too inconclusive to show that the Tax Court was in error in treating Mr. Ruscher as the sole transferrer. With this observation, we are content to affirm the decision on the opinion of the Tax Court, 20 T.C. 272.

2

Affirmed.