WACHTELL, LIPTON, ROSEN KATZ, DAVID M. EINHORN, TAX MATTERS PARTNER, PETITIONER-APPELLEE, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLANT. No. 610, Docket 93-4108.United States Court of Appeals, Second Circuit.Argued November 18, 1993. Decided June 6, 1994. Page 292 [EDITORS’ NOTE: THIS PAGE CONTAINS HEADNOTES. HEADNOTES ARE NOT AN OFFICIAL PRODUCT OF THE COURT, THEREFORE THEY ARE NOT […]