SUN OIL COMPANY v. COMMISSIONER

Docket No. 877-73.

35 T.C.M. 173 (1976)

T.C. Memo. 1976-40

Sun Oil Company, Transferee, Sunray DX Oil Company and Subsidiaries, Transferor v. Commissioner.

United States Tax Court.

Filed February 17, 1976.


Attorney(s) appearing for the Case

Buford P. Berry and Michael J. Henry, 23rd Floor, Republic National Bank Bldg., Dallas, Tex., for the petitioner. Tom G. Parrott, for the respondent.


Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined the following deficiencies in the Federal income tax of Sunray DX Oil Company and its subsidiaries, and notified petitioner that it was liable for the deficiencies as transferee of the assets of the said corporations:

            TYE               Deficiency

      December 31, 1965 .....  $ 14,055
      December 31, 1966 .....    47,806
      December 31, 1967 ......

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