CONTINENTAL GRAIN COMPANY v. COMMISSIONER

Docket No. 34157-84, 34163-84, 34164-84.

56 T.C.M. 900 (1988)

T.C. Memo. 1988-577

Continental Grain Company, Transferee of Allied Mills, Inc., as Successor by Merger to Elm Creek Alfalfa Mills, Inc., et al. v. Commissioner.

United States Tax Court.

Filed December 20, 1988.


Attorney(s) appearing for the Case

Howard A. Smith, Lawrence Weppler, and Richard Bronstein, 1285 Avenue of the Americas, New York, N.Y., for the petitioners. Kevin Flynn and Bruce Wilpon, for the respondent.


Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

By three separate statutory notices, each dated June 28, 1984, respondent determined liability against petitioner, as transferee of Allied Mills, Inc., and predecessor corporations, for the years and in the amounts as follows:

                    Fiscal
      Docket         Year
       No.          Ended           Transferor                  ...

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