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ERLICH v. COMMISSIONER

Docket No. 4871-67.

54 T.C. 1231 (1970)

ISRAEL J. ERLICH AND RUTH ERLICH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 10, 1970.

Attorney(s) appearing for the Case

Sidney J. Matzner, for the petitioners.

Robert H. Feldman, for the respondent.

OPINION

FAY, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1965 in the amount of $1,911.34.

The only issue for decision is whether a sole proprietorship using the reserve method for bad debts is required to restore the reserve to income when it transfers its accounts receivable to a corporation in a section 3511 transfer.

All of the facts have been fully...

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