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COLLEGIATE CAP AND GOWN COMPANY v. COMMISSIONER

Docket No. 4018-69.

37 T.C.M. 960 (1978)

T.C. Memo. 1978-226

Collegiate Cap and Gown Company, Transferee v. Commissioner.

United States Tax Court.

Filed June 19, 1978.

Attorney(s) appearing for the Case

William A. Cromartie, Glen H. Kanwit, and Garland H. Allen, One First National Plaza, Chicago, Ill., for the petitioner. James F. Hanley, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

We have previously held petitioner to be liable as transferee of Cap and Gown Co. (hereafter Cap and Gown) under section 6901.1 Collegiate Cap and Gown Company, Alleged Transferee of Cap and Gown Company v. Commissioner [Dec. 31,639], 59 T.C. 449 (1972). We must now determine the extent of that liability. Respondent disallowed a portion...

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