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CHANEY & HOPE, INC. v. COMMISSIONER

Docket No. 12431-78.

80 T.C. 263 (1983)

CHANEY & HOPE, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 24, 1983.

Attorney(s) appearing for the Case

Robert L. Trimble and Thomas R. Helfand, for the petitioner.

William P. Hardeman, for the respondent.

SCOTT, Judge:

Respondent determined liabilities of petitioner Chaney & Hope, Inc., as transferee based upon deficiencies in income tax of its transferor, Alps Corp., for its fiscal years ended September 30, 1973, September 30, 1974, and the period October 1, 1974, through July 31, 1975, in the respective amounts of $4,919.20, $5,138.38, and $6,876.93.

The issue for decision is whether Alps Corp. was availed of during each of its fiscal years ended...

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