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POIRIER & McLANE CORPORATION v. COMMISSIONER

Docket No. 2662-72.

63 T.C. 570 (1975)

POIRIER & McLANE CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 10, 1975.

Attorney(s) appearing for the Case

Edward S. St. John and Thomas P. Dougherty, for the petitioner.

Rufus H. Leonard, Jr., for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for 1964 in the amount of $624,485.37. Some of the issues have been settled, and the sole issue remaining for decision is whether petitioner is entitled to a deduction for 1964 under section 461(f)1 for the amount of funds transferred in trust under an instrument reciting that the...

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