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McDONALD v. COMMISSIONER

Docket Nos. 76938-76943.

36 T.C. 1108 (1961)

BERTHA GASSIE MCDONALD, TRANSFEREE, ET AL., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 20, 1961.

Attorney(s) appearing for the Case

Byron R. Kantrow, Esq., for the petitioners.

S. George Voss, Esq., for the respondent.

OPINION.

FISHER, Judge:

Respondent determined a deficiency of $13,863.66 in income taxes against petitioners as transferees of assets of The Oaks, Incorporated, In Liquidation (hereinafter referred to as the corporation).

The sole practical issue before us is whether certain State income taxes arising out of and allocable to gains from the sale of real estate, with respect to which the corporation was entitled to nonrecognition of gains under...

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