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DURKIN v. COMMISSIONER

Docket Nos. 29548-89, 29549-89, 29550-89, 29551-89.

67 T.C.M. 1932 (1994)

T.C. Memo. 1994-6

James J. Durkin, Jr., et al. v. Commissioner.

United States Tax Court.

Filed January 10, 1994.

Attorney(s) appearing for the Case

James J. Durkin, Jr., pro se. Michael P. Corrado, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined transferee liability of $274,261 against each of the petitioners based upon our decision in Barbara Coal Co. v. Commissioner [Dec. 44,197(M)], T.C. Memo. 1987-466, affd. without opinion 853 F.2d 916 (3d Cir. 1988) (hereinafter the corporate taxpayer in that case will be referred to as Barbara Coal), wherein we decided that there was...

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