SWALLOWS HOLDING, LTD. v. COMMISSIONER of INTERNAL REVENUE, Appellant. No. 06-3388.United States Court of Appeals, Third Circuit.Argued on September 25, 2007. Opinion Filed February 15, 2008. Appeal from the United States Tax Court, 126 T.C. 96. Page 163 [EDITORS’ NOTE: THIS PAGE CONTAINS HEADNOTES. HEADNOTES ARE NOT AN OFFICIAL PRODUCT OF THE COURT, THEREFORE THEY […]