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HONBARRIER v. COMMISSIONER

Docket Nos. 9053-97, 9054-97.

115 T.C. 300 (2000)

ARCHIE L. AND LOUISE B. HONBARRIER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT HONBARRIER, INC., FORMERLY CENTRAL TRANSPORT, INC., SUCCESSOR TO COLONIAL MOTOR FREIGHT LINE, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 29, 2000.

Attorney(s) appearing for the Case

Frederick Brook Voght and Shane T. Hamilton, for petitioners.

Ross A. Rowley and Steven M. Webster, for respondent.

RUWE, Judge:

Respondent determined a deficiency in Archie L. and Louise B. Honbarrier's Federal income tax for 1993 in the amount of $2,090,149. Respondent determined a deficiency in Colonial Motor Freight Line, Inc.'s (Colonial) Federal income tax for 1993 in the amount of $27,374.

The sole issue for decision is whether the merger of Colonial into Central Transport, Inc. (Central), on December 31, 1993, qualifies...

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