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SIMMONDS PRECISION PRODUCTS, INC. v. COMMISSIONER

Docket No. 3130-76.

75 T.C. 103 (1980)

SIMMONDS PRECISION PRODUCTS, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 14, 1980.

Attorney(s) appearing for the Case

Sidney I. Roberts, Laurence Goldfein, and Lary Wolf, for the petitioner.

Larry Kars, for the respondent.

HALL, Judge:

Respondent determined deficiencies in petitioner's income tax as follows:

          Year                         Deficiency

          1967 ..................     $157,101.66
          1968 ..................    1,146,581.30
          1969 ..................      238,562.22

Petitioner exchanged its stock and options for patents and other rights owned by Sir Oliver Simmonds and/or his wholly owned corporations...

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