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SPECIALIZED SERVICES, INC. v. COMMISSIONER

Docket No. 17054-79.

77 T.C. 490 (1981)

SPECIALIZED SERVICES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 25, 1981.

Attorney(s) appearing for the Case

James E. Johnson, Jr., and Francis J. Blanchfield, Jr., for the petitioner.

Charles P. Hanfman, for the respondent.

SCOTT, Judge:

Respondent determined a deficiency in petitioner's income tax for taxable year 1976 in the amount of $156,756.

The only issue for decision is whether amounts transferred on December 31, 1976, by one of petitioner's subsidiary corporations to a bank-managed "Escrow Trust Fund," which the subsidiary established to hold funds sufficient in amount for the satisfaction of contested accident claims filed...

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