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LA RUE v. COMMISSIONER

Docket Nos. 22164-80, 22165-80, 1014-81, 3726-81, 20879-81, 21096-81, 23909-81, 21199-82, 1867-83.

90 T.C. 465 (1988)

JOSEPH W. LA RUE, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 21, 1988.

Attorney(s) appearing for the Case

James E. Tyrrell, Jr., Hunter L. Prillaman, Kenneth M. Hart, William O'C. Harnisch, and Joseph E. Boury, for the petitioners.

Laurence D. Ziegler and Theodore R. Leighton, for the respondent.

GERBER, Judge:

This is a consolidated action involving seven former general partners of Goodbody & Co., a broker-dealer in securities and commodities. This action is for redetermination of deficiencies arising out of the financial collapse of the Goodbody partnership and the accession to its assets and liabilities by Merrill, Lynch, Pierce, Fenner & Smith, Inc. (Merrill Lynch). The issues for decision are: (1) Whether reserves reflecting "back office...

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