Tannenwald, Judge: Respondent determined a deficiency in the corporate income tax for 1973 of the transferor, Buffalo Tool Die Manufacturing Co., Inc. (hereinafter Buffalo Tool or the corporation), of $403,541, based upon adjustments for depreciation recapture under section 1245. 1 He determined that petitioners Peter Hosta, Jr. (hereinafter Hosta), and Eleanor Hosta are l…
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