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TOMLINSON FLEET CORPORATION v. COMMISSIONER

Docket No. 5491-64.

25 T.C.M. 59 (1966)

T.C. Memo. 1966-13

Tomlinson Fleet Corporation v. Commissioner.

United States Tax Court.

Filed January 17, 1966.

Attorney(s) appearing for the Case

Scott H. Elder, 1208 Terminal Tower, Cleveland, Ohio, for the petitioner. Joseph T. Kane, for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

Respondent determined a deficiency in income tax for 1957 in the amount of $73,748.87. The issue is whether Tower Transit Corporation is a corporation having a tax identity separate from petitioner, and whether in 1960 petitioner sold a vessel to Tower and sustained a loss in 1960, which is deductible under section 165(a).

Findings of Fact

The stipulated facts are so found and are incorporated...

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