Legal Opinion

A. T. Newell Realty Co. v. Commissioner

United States Tax Court

Decided October 30, 1969No. 2566-68, 2565-68Published

1Opinion of the Court

Quealy, Judge:

The respondent determined a deficiency in income tax for the A. T. Newell Realty Co. (a Pennsylvania corporation) for the year ended December 31,1965, in the amount of $32,672.23. Notices of deficiency were addressed to the corporation in care of Leo J. Gal-lina and D. W. Daly, trustees for the stockholders and to the trustees on behalf of the stockholders as transferees. Leo J. Gallina and D. W. Daly have stipulated that they are liable as transferees for any deficiency in income taxes determined to be due from the A. T. Newell Realty Co.

The only issue involved is whether in…

2Cases cited5 opinions

  1. Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
  2. 44 West 3rd Street Corp. v. CommissionerUnited States Tax Court · 1963
  3. Wendell v. CommissionerCourt of Appeals for the Second Circuit · 1964
  4. Covered Wagon, Inc. v. CommissionerCourt of Appeals for the Eighth Circuit · 1966
  5. Morton v. United StatesDistrict Court, W.D. Missouri · 1966

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