PER CURIAM:
The question presented is whether Action Distributing Company, Inc. (hereinafter "Action") is entitled as United Beverage Wholesalers, Inc.'s (hereinafter "United") transferee to a deduction for leasehold improvement expenditures which remained unamortized when the United/Byrne leases were terminated. The Tax Court held that Action was not entitled to a deduction because the terminations of the leases effected a liquidating distribution to Byrne.
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