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HARBOR HOLDING COMPANY OF NEVADA v. COMMISSIONER

Docket Nos. 106028, 106027, 106029, 106030, 106031.

1 T.C.M. 59 (1942)

Harbor Holding Company of Nevada (a Dissolved Corporation), A. S. Henderson, Roger Foley, and Louise Graham, as Liquidating Trustees, et al. v. Commissioner.

United States Tax Court.

Entered November 10, 1942.

Attorney(s) appearing for the Case

J. D. Brady, Esq., 433 S. Spring St., Los Angeles, Calif., for the petitioners. E. A. Tonjes, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, J.:

The respondent has determined a deficiency in income for the year 1938, in the amount of $17,202.70. The deficiency results from a determination that the assets of the Harbor Holding Company of Nevada, a dissolved corporation, were sold by its stockholders on behalf of petitioner, so that the sale of assets was a sale by petitioner, and petitioner realized a profit of $120,923.1

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