Adirondack League Club, Petitioner-appellant, v. Commissioner of Internal Revenue, Respondent-appellee, 458 F.2d 506 (2d Cir. 1972)

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US Court of Appeals for the Second Circuit - 458 F.2d 506 (2d Cir. 1972) Argued May 4, 1972. Decided May 5, 1972

Hugh R. Jones, Utica, N. Y. (Evans, Burdick, Severn & Jones, Utica, N. Y., of counsel), for petitioner-appellant.

Michael L. Paup, Atty., Tax Division, Dept. of Justice (Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Thomas L. Stapleton, Attys., Tax Division, Dept. of Justice, of counsel), for appellee.

Before KAUFMAN, ANDERSON, and MANSFIELD, Circuit Judges.


The judgment is affirmed on the opinion of Judge Withey for a majority of the Tax Court. 55 T.C. 796. The decision of this Court is not to be construed as necessarily rejecting the rationale advanced by the concurring opinions in the Tax Court.