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COLLEGIATE CAP & GOWN CO. v. COMMISSIONER

Docket No. 4018-69.

59 T.C. 449 (1972)

COLLEGIATE CAP AND GOWN COMPANY, ALLEGED TRANSFEREE OF CAP AND GOWN COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 20, 1972.

Attorney(s) appearing for the Case

William A. Cromartie and Donna C. Rankin, for the petitioner

James F. Hanley, Jr., for the respondent.

SIMPSON, Judge:

The respondent determined that the petitioner was liable as transferee for deficiencies in the income tax of Cap & Gown Co. for the fiscal years 1963 and 1964 in the amounts of $135,827 and $163,958, respectively. The issues in this case have been severed, and the only issue to be decided herein is whether the petitioner is liable as a transferee of Cap & Gown Co. under section 6901, I.R.C. 1954.1

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