JOHN T. STEWART III TRUST v. COMMISSIONER

Docket Nos. 1084-72 - 1087-72.

63 T.C. 682 (1975)

JOHN T. STEWART III TRUST, FIRST NATIONAL BANK OF OMAHA, TRUSTEE, TRANSFEREE, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 19, 1975.


Attorney(s) appearing for the Case

James W. R. Brown, T. Geoffrey Lieben, and Lyle E. Strom, for the petitioners.

Ronald M. Frykberg, for the respondent.


WILES, Judge:

The respondent has determined that the petitioners are liable, as transferees, for deficiencies in Federal income taxes due from the National Co. of Omaha, transferor, for the taxable years ended October 31, 1962, and October 31, 1965, as follows:

             Year                              Deficiency

         Oct. 31, 1962 ---------------------    $8,148.00
         Oct. 31, 1965 ---------------------   221,927...

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