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J. UNGAR, INC. v. COMMISSIONER

Docket Nos. 51039, 51040.

26 T.C. 331 (1956)

J. UNGAR, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. JESSE UNGAR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 25, 1956.

Attorney(s) appearing for the Case

Adrian W. DeWind, Esq., and Richard H. Paul, Esq., for the petitioners.

Ellyne E. Strickland, Esq., and Charles B. Markham, Esq., for the respondent.

These consolidated proceedings involve a deficiency in income and excess profits taxes determined against petitioner J. Ungar, Inc., for the taxable year ended February 28, 1951, in the amount of $31,957.21, and a deficiency in like amount against petitioner Jesse Ungar, as transferee of said corporation.

The sole issue to be decided is whether petitioner J. Ungar, Inc., having distributed the right to receive certain brokerage...

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