Legal Opinion
Andrew Crispo Gallery, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided February 22, 1994No. 1766, Docket 93-4036PublishedCited by 33 opinions
1Opinion of the Court
VAN GRAAFEILAND, Circuit Judge:
Andrew Crispo Gallery, Inc. (“Crispo Gallery” or “the Gallery”) appeals from a decision of the United States Tax Court (Cohen, J.) which determined a deficiency of $2,001,-792.14 in income tax for the 1987 taxable year. For the reasons that follow, we affirm in part and vacate and remand in part.
Crispo Gallery began operations in New York City in 1973. It bought and sold artwork for its own account, sold artwork on consignment, and held art exhibitions. It did not sell by way of auction. Andrew Crispo became the Gallery’s president and sole shareholder in 1980,…
2Cases cited44 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Elkins v. United StatesSupreme Court of the United States · 1960
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- United States v. Whiting Pools, Inc.Supreme Court of the United States · 1983
- Commissioner v. DubersteinSupreme Court of the United States · 1960
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3Cited by33 opinions
- United States v. LetscherDistrict Court, S.D. New York · 1999
- United States v. MyersDistrict Court, E.D. New York · 2017
- Gene L. Moretti v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1996
- O'Rourke v. United StatesCourt of Appeals for the Second Circuit · 2009
- Principal Life Insurance Company and Subsidiaries v. United StatesUnited States Court of Federal Claims · 2014
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