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JULIO v. COMMISSIONER

Docket No. 9429-75.

69 T.C. 1 (1977)

EDWARD JULIO AND CARL JULIO, TRANSFEREES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 3, 1977.

Attorney(s) appearing for the Case

Bernard Kraft, for the petitioners.

Robert K. Dowd, for the respondent.

OPINION

HALL, Judge:

Respondent determined that petitioners, as transferees of the assets of Claire Construction Co., Inc., are liable for a $5,350.46 deficiency in Claire's corporate income tax for the year 1973, plus interest.

This case was submitted fully stipulated under Rule 122, Tax Court Rules of Practice and Procedure. The sole issue remaining is whether a special adjustments deduction to personal holding

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