D'ANGELO ASSOCIATES, INC. v. COMMISSIONER

Docket No. 4020-75.

70 T.C. 121 (1978)

D'ANGELO ASSOCIATES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 2, 1978.


Attorney(s) appearing for the Case

Joseph P. D'Angelo (an officer), for the petitioner.

George W. Connelly, Jr., for the respondent.


WILBUR, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the taxable year ended June 30, 1970, in the amount of $1,453.44. Because of concessions made by the parties, the following questions remain for our decision:

(1) What is the proper basis for depreciating assets petitioner acquired shortly after incorporation. This question turns upon whether the transfer of these assets to petitioner constituted a nontaxable exchange...

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