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MARTELL BUILDERS, INC. v. COMMISSIONER

Docket Nos. 3700-62, 3701-62.

23 T.C.M. 1501 (1964)

T.C. Memo. 1964-250

Martell Builders, Inc., (a dissolved corporation) v. Commissioner. American Savings & Loan Association v. Commissioner.

United States Tax Court.

Filed September 23, 1964.

Attorney(s) appearing for the Case

Arthur B. Willis, 615 S. Flower St., Los Angeles, Calif., and Dudley M. Lang, for the petitioners. Michael P. McLeod, for the respondent.

[Memorandum Findings of Fact and Opinion]

DAWSON, Judge:

In these consolidated proceedings respondent determined a deficiency in the income tax of Martell Builders, Inc., Docket No. 3700-62, for the fiscal year ended May 31, 1957, in the amount of $303,726.53, and asserted transferee liability against American Savings & Loan Association, Docket No. 3701-62, in a like amount. The issues for decision are:

(1) Whether respondent erred in disallowing...

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