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NEWTON INSERT CO. v. COMMISSIONER

Docket No. 7786-70.

61 T.C. 570 (1974)

NEWTON INSERT COMPANY, TRANSFEROR, AND TRIDAIR INDUSTRIES, TRANSFEREE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 30, 1974.

Attorney(s) appearing for the Case

Thomas R. Sheppard and Allan I. Grossman, for the petitioners.

H. Lloyd Nearing, for the respondent.

OPINION

SCOTT, Judge:

Respondent determined that Tridair Industries was liable as transferee for a deficiency of $444,779 for the taxable year ended October 31, 1967, of its transferor, Newton Insert Co. (hereinafter Newton). Newton was dissolved and its assets transferred to Tridair Industries on October 31, 1967, in liquidation under the provisions of section 332 (b), I.R.C. 1954,1

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