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STATE v. COMMISSIONER

Docket No. 1603-67.

27 T.C.M. 1522 (1968)

T.C. Memo. 1968-285

Edward M. State and Lorraine State v. Commissioner.

United States Tax Court.

Filed December 12, 1968.

Attorney(s) appearing for the Case

Richard D. Hobbet, Craig M. Hunt, 5th Fl., 626 E. Wisconsin Ave., Milwaukee, Wis., and J. Bruce Donaldson, for the petitioners. Denis J. Conlon and Robert P. Burke, for the respondent.

Memorandum Findings of Fact and Opinion

MULRONEY, Judge:

Respondent determined a deficiency in petitioner's income tax for 1956 in the amount of $280,386.81. The issues are: (1) Whether petitioners realized income as a result of the transfer by Edward M. State to a corporation controlled by him of his interest in Farmington Funding Corporation in return for cancellation by the controlled corporation of State's indebtedness to it and the assumption of certain...

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