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RICHEY v. COMMISSIONER

Docket Nos. 24966, 24967, 24968, 24971.

19 T.C. 926 (1953)

SIMPSON RICHEY, AS TRANSFEREE OF ASSETS OF WADE AND RICHEY, INCORPORATED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ROBIN ADAIR WADE, AS TRANSFEREE OF ASSETS OF WADE AND RICHEY, INCORPORATED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. LILLIAN PEARL WADE, AS TRANSFEREE OF ASSETS OF WADE AND RICHEY, INCORPORATED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. GENEVIEVE MAE LEE, AS TRANSFEREE OF ASSETS OF WADE AND RICHEY, INCORPORATED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 4, 1953.

Attorney(s) appearing for the Case

Frontis H. Moore, Esq., for the petitioners.

S. Earl Heilman, Esq., for the respondent.

The respondent has determined that each of the petitioners is liable as a transferee for a deficiency in excess profits tax of Wade and Richey, Incorporated, for the calendar year 1940 in the amount of $6,832.12. The deficiency results from the respondent's disallowance of the claim of Wade and Richey, Incorporated, that it was entitled to relief under section 721 of the Internal Revenue Code by reason of part of its income being net abnormal income which is attributable...

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