ALLEN v. COMMISSIONER

Docket Nos. 13283, 13284, 13285.

10 T.C. 413 (1948)

GABE P. ALLEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. THEO. W. PINSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ZACH. K. BRINKERHOFF, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 10, 1948.


Attorney(s) appearing for the Case

George S. Atkinson, Esq., Tom D. Rhodes, Jr., Esq., and Luke B. Garvin, C. P. A., for the petitioners.

John W. Alexander, Esq., for the respondent.


The respondent determined a deficiency of $63,674.30 in income tax against the Allen Building Co. for the part of the year 1944 from January 1 to January 31 during which this corporation was in existence. Other deficiencies, determined for the years 1942 and 1943, have been paid in full. In the deficiency letters transferee liability was asserted against the petitioners as follows:

Gabe P. Allen ------------------------------------------   $66,098.98
Theo. W...

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