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FIRST NATIONAL BANK OF GAINESVILLE v. COMMISSIONER

Docket Nos. 23697-83-23699-83.

88 T.C. 1069 (1987)

THE FIRST NATIONAL BANK OF GAINESVILLE, TRUSTEE, U/A CLARENCE O. BARKER, TRANSFEREE, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 28, 1987.

Attorney(s) appearing for the Case

W. Woodrow Stewart and Steven A. Cornelison, for the petitioners.

Bonnie L. Cameron and Albert L. Sandlin, for the respondent.

WHITAKER, Judge:

Respondent determined petitioners to be liable, as transferees, for deficiencies in Federal income tax of Hall Paving Co., Inc., Transferor (Hall Paving), for the years and in the amounts indicated:

TYE Oct. 31—                  Deficiency2

   1978  ....................    $197.04
   1979  ....................  90,087.75

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