Delia v. Commissioner

Charlie Delia, Transferee v. Commissioner.

Delia v. Commissioner

Docket No. 1149-63.

United States Tax Court

T.C. Memo 1964-329; 1964 Tax Ct. Memo LEXIS 8; 23 T.C.M. (CCH) 2018; T.C.M. (RIA) 64329;

December 23, 1964

Martin J. Welsh, Leader Bldg., Cleveland, Ohio, for the petitioner. John P. Graham, for the respondent.

DAWSON

Memorandum Findings of Fact and Opinion

DAWSON, Judge: Respondent has asserted that petitioner is a transferee of Lath Rite Builders, Inc., based on the following deficiencies and additions to tax assessed against Lath Rite:

Year

Deficiencies

Addition to tax

under Sec. 6651(a),

I.R.C.,…