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STUART v. COMMISSIONER

Docket Nos. 1685-11, 1686-11, 1687-11, 1688-11.

144 T.C. 235 (2015)

WILLIAM SCOTT STUART, JR., TRANSFEREE, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 1, 2015.

Attorney(s) appearing for the Case

Steven Spencer Brown and Denis John Conlon, for petitioners.

H. Barton Thomas, Jr., and George W. Bezold, for respondent.

These four cases have been consolidated for purposes of trial, briefing, and opinion. Little Salt Development Co. (Little Salt or company) is a Nebraska corporation. Petitioners were shareholders of Little Salt in 2003 until, in August, they sold their shares. Respondent determined and assessed a deficiency in Little Salt's 2003...

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