Legal Opinion
Darco Realty Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided April 3, 1962No. 27123_1PublishedCited by 22 opinions
1Opinion of the Court
CLARK, Circuit Judge.
This case arises out of a complex real estate transaction consummated in 1927. By virtue of this transaction, which was conceived and executed by two real estate syndicators, Samuel A. Herzog and Edgar A. Levy, the petitioner, Darco Realty Corporation, controlled by Levy and Herzog, purchased on September 30, 1927, the stock of the 745 — 7th Avenue Corporation. The price paid was $376,-450, of which all but $75,000 constituted an immediate cash outlay. The 745 — 7th Avenue Corporation held a ground lease on the property at that location, for which it paid the fee owner an…
2Cases cited4 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Heil Beauty Supplies, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1952
- Ecco High Frequency Corp. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1948
- George La Monte & Son v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1929
3Cited by22 opinions
- Mennuto v. CommissionerUnited States Tax Court · 1971
- B. Forman Co. v. CommissionerCourt of Appeals for the Second Circuit · 1972
- Federal Cement Title Co. v. CommissionerUnited States Tax Court · 1963
- B. Forman Company, Inc. v. Commissioner of Internal Revenue, McCurdy & Company, Inc. v. Commissioner of Internal Revenue, B. Forman Company, Inc. v. Commissioner of Internal Revenue, McCurdy & Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1972
- Schner-Block Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
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