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HEUSDEN v. COMMISSIONER

Docket Nos. 2358-63, 2357-63.

44 T.C. 491 (1965)

GUY A. VAN HEUSDEN, TRANSFEREE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF E. J. VAN HEUSDEN, DECEASED, TRANSFEREE, MELANIE VAN HEUSDEN, EXECUTRIX, AND TITLE INSURANCE AND TRUST COMPANY, AS SPECIAL ADMINISTRATOR, AND APPLICANT FOR LETTERS OF GENERAL ADMINISTRATION AS SUCCESSOR EXECUTOR TO MELANIE VAN HEUSDEN, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 28, 1965.

Attorney(s) appearing for the Case

Samuel J. Foosaner, for the petitioners.

John J. Hopkins and Julius M. Jacobs, for the respondent.

TRAIN, Judge:

Respondent has asserted that petitioners are liable is transferees of West Cocoa Acres, Inc., for a deficiency in the latter's 1958 income taxes in the amount of $65,668.01. Since petitioners have conceded that they are liable as transferees for any deficiency, the issue for our decision is whether there is any underlying deficiency. This depends upon whether or not West Cocoa Acres, Inc., was a collapsible corporation within the definition of...

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