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RISS v. COMMISSIONER

Docket Nos. 3794-62, 3795-62, 3879-62, 3178-66.

57 T.C. 469 (1971)

RICHARD R. RISS, SR., ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 30, 1971.

Attorney(s) appearing for the Case

Guy A. Magruder, Jr., and Richard M. Erickson, for the petitioners.

Edward G. Lavery, for the respondent.

SUPPLEMENTAL OPINION

IRWIN, Judge:

In our prior opinion in this case, entered May 24, 1971 (56 T.C. 388), we held (issue one) that the gain realized on the sale by Transport Manufacturing & Equipment Co. of Delaware (T.M.E.) of 814 truck trailers should be allocated between T.M.E. and its sister corporation Riss & Co., Inc. (Riss). In addition, we did not decide (issue three) whether T.M.E. could deduct as a...

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