ASSOCIATES INVESTMENT CO. v. COMMISSIONER

Docket No. 1426-69.

59 T.C. 441 (1972)

ASSOCIATES INVESTMENT COMPANY, ALLEGED TRANSFEREE OF THE PROTECTIVE LIFE INSURANCE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 20, 1972.


Attorney(s) appearing for the Case

William A. Cromartie, Patrick A. Heffernan, and Peter B. Freeman, for the petitioner.

Rex A. Guest, for the respondent.


OPINION

SIMPSON, Judge:

The respondent determined that the petitioner was liable as transferee for deficiencies in the income tax of the Protective Life Insurance Co. as follows:

Year                                   Deficiency

1958 ------------------------------    $200,589.67
1959 ------------------------------     156,645.21
1960 ------------------------------     212,785.62
1961 ------------------------------ ...

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