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WARSAW PHOTOGRAPHIC ASSOCIATES, INC. v. COMMISSIONER

Docket No. 2113-79.

84 T.C. 21 (1985)

WARSAW PHOTOGRAPHIC ASSOCIATES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 14, 1985.

Attorney(s) appearing for the Case

Robert A. Jacobs, Nicholas J. Creme, and Lewis Kurfist, for the petitioner.

Richard M. Campbell and Kevin C. Reilly, for the respondent.

CHABOT, Judge:

Respondent determined deficiencies in Federal corporate income tax against petitioner for its taxable years ended June 30, 1974,1 June 30, 1975, and June 30, 1976, in the amounts of $70,040, $58,239, and $34,685, respectively.

After concessions by both sides, the issues for decision are as follows:

(1) Whether a transaction involving a transfer of assets to petitioner qualifies as a reorganization...

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