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FELIX v. COMMISSIONER

Docket No. 4138-78.

41 T.C.M. 1040 (1981)

T.C. Memo. 1981-99

Peter G. Felix and Angie P. Felix v. Commissioner.

United States Tax Court.

Filed March 2, 1981.

Attorney(s) appearing for the Case

Francis X. McCormick and John R. Blasi, 184 Elm St., Westfield, N.J., for the petitioners. Bernard Wishnia, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency of $13,467.22 in petitioners' Federal income tax for 1971. After concessions, the only issue presented is whether two corporations whose stock was sold by petitioners were collapsible corporations within the meaning of section 341.1

Findings of Fact

Some of the facts were stipulated and are so found.

Petitioners Peter...

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