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CHARLOTTE CORPORATION v. COMMISSIONER

Docket Nos. 52608, 68666-68670.

19 T.C.M. 513 (1960)

T.C. Memo. 1960-97

Charlotte Corporation, et al. v. Commissioner.

United States Tax Court.

Filed May 13, 1960.

Attorney(s) appearing for the Case

Norman Sinrich, Esq., Jay O. Kramer, Esq., and Richard C. Flesch, Esq., for the petitioner in Docket No. 52608. Aaron Lewittes, Esq., for the petitioners in Docket Nos. 68666, 68667, 68668, 68669, 68670. Henry L. Glenn, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent has determined a deficiency in the Federal income tax of Charlotte Corporation for the year 1950 in the amount of $31,485.24 by characterizing $100,000 (reported as long-term capital gain from the sale of good will) as ordinary income from the sale of inventories.

On the inconsistent ground that part of the purchase price was in payment for good will, respondent has determined deficiencies...

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