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STORZ v. COMMISSIONER

Docket Nos. 8292-71, 8293-71.

68 T.C. 84 (1977)

ROBERT H. STORZ AND MILDRED T. STORZ, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT ROBERT H. STORZ, TRANSFEREE OF STORZ-WACHOB-BENDER CO., A DISSOLVED CORPORATION v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 26, 1977.

Attorney(s) appearing for the Case

Kent O. Littlejohn and David M. Pedersen, for the petitioners.

Ronald M. Frykberg, for the respondent.

FAY, Judge:

Respondent determined a liability against petitioner Robert H. Storz, as transferee, with respect to a deficiency determined against Storz-Wachob-Bender Co., transferor, in the amount of $58,494.38 for the taxable period April 1, 1966, to February 20, 1967. The issue for decision (docket No. 8293-71) is whether a portion of the amount received by Storz-Wachob-Bender Co. for the sale of its business represented payment for the assignment of income...

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