Legal Opinion

Ogiony v. Commissioner

Court of Appeals for the Second Circuit

Decided February 22, 1980No. Nos. 504-508, Dockets 79-4147, 79-4149, 79-4151, 79-4153, 79-4155PublishedCited by 15 opinions

1Opinion of the Court

MULLIGAN, Circuit Judge:

This is an appeal from a decision of the Tax Court, Cynthia Hall, Judge, 38 T.C.M. 358 (1979). The facts, most of which were stipulated by the parties, are set forth in detail in Judge Hall’s opinion. For the purposes of this appeal, they may be summarized as follows.

Appellants1 or their wholly-owned corporations formed two partnerships, P. Santin, J. & E. Ogiony, A. Stangl — Joint Venture in 1966 (“Garden Partnership”) and Losson Gardens Company in 1969, for the purpose of building rental apartments on certain pieces of underdeveloped real estate in Cheektowaga, New…

2Cases cited5 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
  3. Strong v. CommissionerUnited States Tax Court · 1976
  4. Branerton Corp. v. CommissionerUnited States Tax Court · 1975
  5. Grasavage v. CommissionerUnited States Tax Court · 1979

3Cited by15 opinions

  1. Ourisman v. CommissionerUnited States Tax Court · 1984
  2. Vaughn v. United StatesUnited States Court of Claims · 1983
  3. Gateway Equipment Corp. v. United StatesDistrict Court, W.D. New York · 2003
  4. Ogiony v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1980
  5. Sarkisian v. CommissionerUnited States Tax Court · 1982

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