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ROSENGARTEN v. COMMISSIONER

Docket No. 109041.

1 T.C.M. 872 (1943)

Adolph G. Rosengarten, Transferee v. Commissioner.

United States Tax Court.

Entered April 6, 1943.

Attorney(s) appearing for the Case

Frederick E. S. Morrison, Esq., 1429 Walnut St., Philadelphia, Pa., for the petitioner. Paul E. Waring, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent determined a deficiency in income tax for the year 1940 against petitioner as transferee of the assets of the Falls Company in the sum of $9,401.93. Petitioner has conceded his transferee liability in the event we decide that the Falls Company was liable for the deficiency. The first issue is whether or not the Falls Company properly deducted as a business expense an amount of $227,424.19 paid a life insurance company...

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