GOLDBERG v. COMMISSIONER

Docket Nos. 41243, 41244.

22 T.C. 533 (1954)

NATHAN D. GOLDBERG, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. S. E. WOOD, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 11, 1954.


Attorney(s) appearing for the Case

Geo. S. Atkinson, Esq., and Tom B. Rhodes, Jr., Esq., for the petitioners.

Jackson L. Bailey, Esq., and R. S. Leigh, Esq., for the respondent.


This proceeding involves deficiencies in income tax for the calendar year 1946, asserted against the petitioners as transferees of Pinecrest Housing, Incorporated, a Texas corporation that was dissolved in 1946. The total liability is $6,455.76, which amount has been assessed against each of the petitioners.

On the motion of petitioners the two cases have been consolidated for hearing and disposition. The only question presented is whether the profit realized by Pinecrest...

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