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CALLAN v. COMMISSIONER

Docket Nos. 6025-68, 6026-68.

54 T.C. 1514 (1970)

MICHAEL C. CALLAN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. THOMAS J. CALLAN, JR., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 22, 1970.

Attorney(s) appearing for the Case

Minot W. Tripp, Jr., Samuel Taylor, and Robert M. Winokur, for the petitioners.

John Gigounas, for the respondent.

OPINION

RAUM, Judge:

The Commissioner determined deficiencies of $13,943.28 and $671.86 in the income and personal holding company tax of Callan Investment Co. for the taxable year ended February 28, 1965, and for the taxable period March 1, 1965, to March 12, 1965, respectively. He further determined that petitioners, as transferees of the assets of Callan Investment Co., were jointly and severally liable for the foregoing amounts, plus statutory...

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