GARROW v. COMMISSIONER

Docket No. 4055-63.

43 T.C. 890 (1965)

RALPH R. GARROW AND EUNICE GARROW, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 25, 1965.


Attorney(s) appearing for the Case

Wareham Seaman and Lee M. Galloway, for the petitioners.

David Brennan, for the respondent.


OPINION

ATKINS, Judge:

The respondent determined a deficiency in income tax for the taxable year 1961 in the amount of $6,427.35.

The issues presented are: (1) Whether the respondent's allocation of the basis computed under section 334(c) of the Internal Revenue Code of 1954 among the various assets (including notes and accounts receivable and a claim for income tax refund) received by the petitioner in liquidation of a corporation in proportion...

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