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NEW JERSEY TITLE GUARANTEE AND TRUST COMPANY v. COMMISSIONER

Docket No. 101988.

13 T.C. 674 (1949)

THE NEW JERSEY TITLE GUARANTEE AND TRUST COMPANY (IN LIQUIDATION), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 31, 1949.

Attorney(s) appearing for the Case

Louis Bort, Esq., for the petitioner.

Walt Mandry, Esq., for the respondent.

OPINION.

HARLAN, Judge:

Respondent mailed to the Bank of Lafayette, c/o petitioner, Jersey City, New Jersey (the Bank of Lafayette having been merged with petitioner December 9, 1931, and lost its separate identity) notice of deficiency in income tax for the calendar year 1930 in the amount of $150, as transferee of assets of the New York Mutual Telegraph Co., New York, New York. The sole issue is whether or not petitioner, an insolvent state bank...

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