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BYRD, TRANSFEREE v. COMMISSIONER

Docket Nos. 32626-84, 32699-84.

87 T.C. 830 (1986)

CARLTON L. BYRD, TRANSFEREE OF THE ASSETS OF EASTERN SHORE NURSERY, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT ROBERT H. WILLEY, JR., TRANSFEREE OF THE ASSETS OF EASTERN SHORE NURSERY, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 27, 1986.

Attorney(s) appearing for the Case

Douglas E. Kahle, for the petitioners.

Richard F. Stein, for the respondent.

OPINION

DRENNEN, Judge:

These cases have been consolidated for trial pursuant to Rule 141.1 Respondent determined a deficiency in the Federal income tax of Eastern Shore Nursery of Virginia, Inc. (Eastern Shore or the corporation), for the taxable year 1980 of $113,480.62. Petitioners are liable for this deficiency as transferees of the assets of Eastern Shore. Respondent issued notices of transferee

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