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COLD METAL PROCESS COMPANY v. COMMISSIONER

Docket Nos. 33396, 33397.

25 T.C. 1333 (1956)

THE COLD METAL PROCESS COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. THE LEON A. BEEGHLY FUND, THE UNION NATIONAL BANK OF YOUNGSTOWN, OHIO, TRUSTEE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 30, 1956.

Attorney(s) appearing for the Case

Howard F. Burns, Esq., William H. Fleming, Esq., and L. C. Weiss, C. P. A., for the petitioners.

S. Earl Heilman, Esq., and James F. Kennedy, Jr., Esq., for the respondent.

Respondent determined a deficiency in income tax of the Cold Metal Process Company (hereinafter referred to as Cold Metal) for the year 1949 in the amount of $5,550,140.33 and determined that the Leon Beeghly Fund, the Union National Bank of Youngstown, Ohio, Trustee (hereinafter referred to as Trustee), is liable as transferee for the full amount of the deficiency. (Cold Metal and the Trustee are hereinafter referred to collectively as petitioners.) Respondent also determined...

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