HUYLER'S v. COMMISSIONER

Docket No. 83836.

38 T.C. 773 (1962)

HUYLER'S, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 30, 1962.


Attorney(s) appearing for the Case

Robert S. Ashby, Esq., and Lester M. Ponder, Esq., for the petitioner.

Robert E. Johnson, Esq., for the respondent.


PIERCE, Judge:

Respondent determined deficiencies in the petitioner's income taxes for its fiscal years ended June 30, 1956 and 1957, in the amounts of $37,500 and $640,386.77, respectively.

The issues for decision are:

(1) Whether a corporation which had in 1952 and 1953 experienced substantial changes in its stockownership and in the character of its business — as the result of a chapter X bankruptcy reorganization, the discontinuance...

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