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GARBER INDUS. HOLDING CO. v. COMMISSIONER

Docket No. 10871-01.

124 T.C. 1 (2005)

124 T.C. No. 1

GARBER INDUSTRIES HOLDING CO., INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 25, 2005.

Attorney(s) appearing for the Case

George W. Connelly, Jr., Linda S. Paine, and Phyllis A. Guillory, for petitioner.

Susan K. Greene and Marilyn S. Ames, for respondent.

HALPERN, Judge:

By notice of deficiency dated June 21, 2001, respondent determined deficiencies in petitioner's Federal income taxes for petitioner's 1997 and 1998 taxable (calendar) years in the amounts of $4,916 and $301,835, respectively. The parties have settled all issues save one, leaving for our decision only the question of whether a 1998 stock sale between siblings that increased one sibling's percentage ownership of petitioner by more than 50 percentage...

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