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DITTLER BROS., INC. v. COMMISSIONER

Docket No. 5438-78T.

72 T.C. 896 (1979)

DITTLER BROTHERS, INCORPORATED, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 27, 1979.

Attorney(s) appearing for the Case

William L. Kinzer, David W. Siegel, and Philip J. Marzetti, for the petitioner.

Robert L. Ash, for the respondent.

OPINION

FORRESTER, Judge:

This is an action for declaratory judgment pursuant to section 7477(a).1

Petitioner Dittler Brothers, Inc., filed a request for a determination of the taxable status of a proposed transaction with the National Office, Technical Services Branch, Washington, D.C., on June 3, 1976. Therein, petitioner requested, inter alia, that respondent find, and so rule, that the transfer of cash and...

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