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SUBSCRIPTION TELEVISION, INC. v. C. I. R.

No. 74-3145.

532 F.2d 1021 (1976)

SUBSCRIPTION TELEVISION, INC., Successor By Merger to John Blue Company, Inc., Subscription Television, Inc., Successor By Merger to Blue Equipment Company, Inc., Subscription Television, Inc., Successor By Merger to Rex, Inc., Subscription Television, Inc., Successor By Merger to Blue Company, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

June 7, 1976.

Attorney(s) appearing for the Case

Donald W. McCoy, Fayetteville, N.C., for petitioners-appellants.

Scott P. Crampton, Asst. Atty. Gen., Myron C. Baum, Deputy Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Washington, D.C., Gilbert E. Andrews, Jr. Acting Chief, Leonard J. Henzke, Jr., Atty., Michael J. Roach, Atty., App. Section, Tax Div., Dept. of Justice, Washington, D.C., Meade Whitaker, Chief Counsel, Michael Zimmerman, Atty., Internal Revenue Service, Washington, D.C., for respondent-appellee.

Before GOLDBERG, DYER and SIMPSON, Circuit Judges.

SIMPSON, Circuit Judge:

Subscription Television, Inc. (taxpayer) appeals from the June 6, 1974 decisions of the United States Tax Court which determined deficiencies in the total amount of $47,589.29 against it, as successor by merger to each of four predecessor companies, John Blue Company, Inc., Blue Equipment Company, Inc., Rex, Inc. and Blue Company.1 We affirm the ruling of the Tax Court.

I. THE FACTS

The facts,...

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