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McCOURT v. COMMISSIONER

Docket No. 19346.

15 T.C. 734 (1950)

L. T. McCOURT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 28, 1950.

Attorney(s) appearing for the Case

W. G. Boone, Esq., and Charles H. Davis, Esq., for the petitioner.

S. Earl Heilman, Esq., for the respondent.

Under section 311 (a) (2) of the Internal Revenue Code,1 respondent has proposed a fiduciary liability against petitioner, as arising under sections 3466 and 3467 of the Revised Statutes, resulting from the distribution by petitioner of assets of the Merchants Warehouse Co. upon its liquidation without first satisfying a liability of that company for unpaid income and declared value excess profits taxes in the respective amounts of $1,762.87 and...

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