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MESSER v. COMMISSIONER

Docket Nos. 6523-65-6525-65.

52 T.C. 440 (1969)

SIDNEY MESSER, TRANSFEREE, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 16, 1969.

Attorney(s) appearing for the Case

Julius G. Hirsch, for the petitioners.

Frank N. Panza, for the respondent.

DAWSON, Judge:

Respondent has asserted against petitioners transferee liability for an income tax deficiency determined to be due from Tel-O-Tube Corp. of America, transferor, for the taxable year ended September 30, 1961, in the amount of $39,158.43 and an addition to tax under section 6651 (a), I.R.C. 1954,2 in the amount of $9,789.61.

We are confronted with one issue: Did Tel-O-Tube Corp. of America, subsequent to its...

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