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MANN v. COMMISSIONER

Docket Nos. 8811-73, 8852-73, 8853-73.

35 T.C.M. 342 (1976)

T.C. Memo. 1976-78

William C. Mann, Transferee, et al. v. Commissioner.

United States Tax Court.

Filed March 16, 1976.

Attorney(s) appearing for the Case

Lyman T. Burgess, for the petitioners. Peter J. Panuthos, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined that petitioners are liable, as transferees, for the income tax deficiency of Airport Industrial Park, Inc., transferor, for its taxable year ending December 31, 1969. The deficiency is $79,878.00. The issues are: (1) Whether the transferor was a collapsible corporation within the meaning of section 3412 and was, therefore, not entitled to benefit from...

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