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G C SERVICES CORP. v. COMMISSIONER

Docket No. 11193-76.

73 T.C. 406 (1979)

G C SERVICES CORP., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 3, 1979.

Attorney(s) appearing for the Case

Charles W. Hall, Kenneth W. Gideon, and Gerald W. Haddock, for the petitioners.

Daniel A. Taylor, Jr., for the respondent.

SIMPSON, Judge:

The Commissioner determined a deficiency of $168,000 in the petitioner's Federal income tax for 1972. The petitioner subsequently claimed an overpayment of $93,848 for the same year. The issues for decision are: (1) What portion, if any, of the payment which the petitioner made to purchase shares of its own stock and to settle claims of the seller of such stock is allocable to the settlement of such claims, and (2) if a portion is so allocable...

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