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A. T. NEWELL REALTY CO. v. COMMISSIONER

Docket Nos. 2566-68, 2565-68.

53 T.C. 130 (1969)

A. T. NEWELL REALTY COMPANY, C/O LEO J. GALLINA & D. W. DALY, TRUSTEES AND TRANSFEREES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT LEO J. GALLINA & D. W DALY, TRUSTEES FOR THE STOCKHOLDERS OF A. T. NEWELL REALTY COMPANY, TRANSFEREES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 30, 1969.

Attorney(s) appearing for the Case

R. K. Conrad, for the petitioners.

D. Alden Newland, for the respondent.

QUEALY, Judge:

The respondent determined a deficiency in income tax for the A. T. Newell Realty Co. (a Pennsylvania corporation) for the year ended December 31, 1965, in the amount of $32,672.23. Notices of deficiency were addressed to the corporation in care of Leo J. Gallina and D. W. Daly, trustees for the stockholders and to the trustees on behalf of the stockholders as transferees. Leo J. Gallina and D. W. Daly have stipulated that they are liable as transferees...

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