UNITED STATES HOLDING CO. v. COMMISSIONER

Docket No. 92152.

44 T.C. 323 (1965)

UNITED STATES HOLDING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 9, 1965.


Attorney(s) appearing for the Case

C. Hugh Friedman, for the petitioner.

Michael P. McLeod, for the respondent.


OPINION

FAY, Judge:

The Commissioner determined deficiencies in income tax for the taxable years 1954 and 1956 against Pasadena First National Bank, a transferor corporation, in the respective amounts of $22,983.70 and $295,430.78. This proceeding involves the liability of the petitioner as transferee of the assets of the aforementioned transferor corporation.1 The parties by agreement...

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