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BONAIRE DEVELOPMENT CO. v. COMMISSIONER

Docket No. 4396-69.

76 T.C. 789 (1981)

BONAIRE DEVELOPMENT COMPANY, A CALIFORNIA CORPORATION, SUCCESSOR BY MERGER TO BRANJON, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 14, 1981.

Attorney(s) appearing for the Case

Harry Margolis, for the petitioner.

Henry E. O'Neill, for the respondent.

OPINION

SCOTT, Judge:

Respondent has determined that petitioner is liable as transferee of the assets of Branjon, Inc., which, in turn, was transferee of the assets of N & V Realty Corp., for a deficiency in the Federal income tax of N & V Realty Corp. for the taxable year 1964 in the amount of $3,748.01. Petitioner admitted in its amended petition that it is the transferee of the assets of N & V Realty Corp. and Branjon, Inc.

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