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VERN REALTY, INC. v. COMMISSIONER

Docket No. 1294-71.

58 T.C. 1005 (1972)

VERN REALTY, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 21, 1972.

Attorney(s) appearing for the Case

Lester H. Salter and James R. McGowan, for the petitioner.

Barry J. Laterman, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency of $9,396.77 in petitioner's Federal income tax for its taxable year ending June 30, 1968. The only issue presented for decision is whether, within the meaning of section 337(a),1 all of the assets of petitioner, less assets retained to meet claims, were distributed within 12 months after the adoption of a plan of complete liquidation.

FINDINGS OF FACT

Vern...

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