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LEACH v. COMMISSIONER

Docket No. 39428.

21 T.C. 70 (1953)

J. WARREN LEACH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 19, 1953.

Attorney(s) appearing for the Case

Erle Pettus, Jr., Esq., for the petitioner.

Homer F. Benson, Esq., for the respondent.

The Commissioner has determined a deficiency of $3,286.74, plus negligence penalty of $164.34, in the income tax of Euclid Circle Homes, Inc., for the taxable year ending October 31, 1947. He has determined that the petitioner is liable for that deficiency and penalty as transferee of the assets of the corporation.

The Commissioner contends that one-half ($2,625) of the $5,250 salary paid petitioner by Euclid Circle Homes,...

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