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VERNON C. NEAL, INC. v. COMMISSIONER

Docket No. 4635-62.

23 T.C.M. 873 (1964)

T.C. Memo. 1964-145

Vernon C. Neal, Inc. v. Commissioner.

United States Tax Court.

Filed May 25, 1964.

Attorney(s) appearing for the Case

Sam G. Winstead Republic National Bldg., Dallas, Tex., for the petitioner. Thomas J. Moroney, Jr., for the respondent.

Memorandum Opinion

BRUCE, Judge:

The respondent determined a deficiency in the amount of $736,402.47 in the income tax of the petitioner for the fiscal year ended February 28, 1958. The sole issue for decision is whether intercompany profits eliminated in prior taxable years in consolidated returns filed by the petitioner and its subsidiaries become realized upon the sale of all the stock of the subsidiaries...

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