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WILLIAMS v. COMMISSIONER

Docket Nos. 1553-80, 1566-80.

47 T.C.M. 846 (1984)

T.C. Memo. 1984-11

Jan T. Williams v. Commissioner. Anderson T. Williams v. Commissioner.

United States Tax Court.

Filed January 5, 1984.

Attorney(s) appearing for the Case

Michael L. Cook and Donald J. Reese, P.O. Box 1148, Austin, Tex., for the petitioners. Juan F. Vasquez, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

In these consolidated cases, respondent determined that petitioners were liable, as transferees of Esbanco, Inc.'s assets under section 6901,1 for a $116,045.80 deficiency in the corporation's Federal income tax for its taxable year ending August 31, 1975.

After concessions,2 the issues remaining for decision are: (1) Whether the rent Esbanco...

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