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SPIELMAN v. COMMISSIONER

Docket No. 9934-74.

37 T.C.M. 685 (1978)

T.C. Memo. 1978-154

Warren L. Spielman v. Commissioner.

United States Tax Court.

Filed April 20, 1978.

Attorney(s) appearing for the Case

F. Roger Hemker, and Mark R. Gale, 1800 Equitable Bldg., 10 South Bway., St. Louis, Mo., for the petitioner. Dale L. Newland, for the respondent.

Memorandum Opinion

DAWSON, Judge:

Respondent determined that petitioner was liable, as the transferee of the assets of General Development Corporation, Inc., for the unpaid income tax of $73,843.31, plus interest as provided by law, due from the corporation for the taxable year ended April 30, 1967. Due to a concession by petitioner, the only issue remaining for our decision is whether the nonrecognition provisions of section 3371

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