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CLAYTON v. COMMISSIONER

Docket Nos. 3040-68, 3041-68.

52 T.C. 911 (1969)

FRANKLIN CLAYTON, TRANSFEREE OF C.T.M., INC., FORMERLY CLAWSON TRANSIT MIX, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. MILAN UZELAC, TRANSFEREE OF C.T.M., INC., FORMERLY CLAWSON TRANSIT MIX, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 2, 1969.

Attorney(s) appearing for the Case

Donald G. Tripp, for the petitioners.

Robert T. Hollohan, for the respondent.

OPINION

TIETJENS, Judge:

The Commissioner determined that petitioners in these consolidated proceedings are liable as transferees for a deficiency of $91,607.65 in income tax of Clawson Transit Mix, Inc., transferor, for the period from April 1, 1964, to August 31, 1964. The petitioners concede they are liable as transferees for any amount of such deficiency which may be determined.

We must decide only whether the recognition provision of...

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