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BUFFALO TOOL & DIE MFG. CO. v. COMMISSIONER

Docket No. 6553-77.

74 T.C. 441 (1980)

BUFFALO TOOL & DIE MANUFACTURING CO., INC., TRANSFEROR, PETER HOSTA, JR., AND ELEANOR HOSTA, TRANSFEREES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 27, 1980.

Attorney(s) appearing for the Case

Paul R. Comeau and Victor T. Fuzak, for the petitioners.

Louis J. Zeller, Jr., for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency in the corporate income tax for 1973 of the transferor, Buffalo Tool & Die Manufacturing Co., Inc. (hereinafter Buffalo Tool or the corporation), of $403,541, based upon adjustments for depreciation recapture under section 1245.1 He determined that petitioners Peter Hosta, Jr. (hereinafter Hosta), and Eleanor Hosta are liable as transferees of Buffalo Tool as follows:

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