Frischkorn Development Co. v. Commissioner

OPINION.

Maequette:

These proceedings were consolidated. Docket Nos. 80496 and 42452 involve deficiencies in income tax for fiscal years ended June 80, as follows:

1923_ $647.89

1924_ 10,575.54

1925_ 1,439.52

1926_ 1,630.44

1927_ 1, 436. 02

Docket No. 35170 involves the liability of the petitioner as a transferee of the property of the Frischkorn Homes Co., hereafter referred to as the Homes Co., for a deficiency in income tax for the calendar year 1922 in the amount of $28,881.84 and a delinquency jienalty of $7,095.46. The petitioner admits its liability as a transferee of, but disputes the amount…