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BELLIN v. COMMISSIONER

Docket Nos. 2159-74, 2177-74.

65 T.C. 676 (1975)

BENJAMIN AND LILLIAN BELLIN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT MEYER AND EVA THOMAS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 31, 1975.

Attorney(s) appearing for the Case

Frank L. Schiavo and Robert I. Tuteur, for the petitioners.

Gerald V. May, Jr., for the respondent.

OPINION

DRENNEN, Judge:

Petitioners Benjamin and Lillian Bellin and petitioners Meyer and Eva Thomas presently reside in Philadelphia, Pa. Both the Bellins and the Thomases will hereafter be referred to collectively as petitioners.

Respondent determined that petitioners were liable as transferees of the assets of Hamilton Homes, Inc., transferor, for deficiencies in income tax and addition to tax under section 6651(a), I.R.C. 1954,

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