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SNYDER v. COMMISSIONER

Docket Nos. 7616-78, 7617-78.

41 T.C.M. 1416 (1981)

T.C. Memo. 1981-216

Atlee D. Snyder v. Commissioner. Atlee D. Snyder, Transferee of the Assets of Snyder Enterprises, Inc. v. Commissioner.

United States Tax Court.

Filed April 30, 1981.

Attorney(s) appearing for the Case

Harry W. Schmuck, 401 Central Trust Tower, Canton, Ohio, James C. Herndon, and Sam D. Bartlo, for the petitioner. Richard S. Bloom, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined deficiencies of $160,650.05 and $125,476.11 in petitioner's income taxes for the taxable years ending December 31, 1973 and December 31, 1974. After concessions by petitioner, the issue remaining is whether Synder Enterprises, Inc. (Snyder, Inc.), completely liquidated within the statutory period prescribed by section 337(a),1 thereby entitling it...

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