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TROY STATE UNIVERSITY v. COMMISSIONER

Docket No. 7516-72.

62 T.C. 493 (1974)

TROY STATE UNIVERSITY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 9, 1974.

Attorney(s) appearing for the Case

James M. Scott, for the petitioner.

Roy S. Fischbeck, for the respondent.

OPINION

TIETJENS, Judge:

The Commissioner determined that Troy State University (hereafter petitioner) is liable for $5,559.26, plus interest, as transferee of assets of Beard Memorial Hospital, Inc. (hereafter transferor), for the taxable period March 1, 1966, to October 1, 1966.

The issue for decision is whether amounts treated as gain under section 1245.1 are excludable from transferor's gross income by reason...

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