United States Tax Court
Albany Car Wheel Company, Inc.
Petitioner,
v.
Commissioner of Internal Revenue,
Respondent

Docket No. 90211
Date of Decision: August 8, 1963
Judge:  Raum.
Parallel Citations: 40 T.C. 831
T Corp. purchased the operating assets of a predecessor company,
and continued the business of the predecessor. As part of the purchase
agreement T was required to procure a release of the predecessor‘s
liability under a union contract for severance pay to employees upon
permanent closing of the plant. T obtained such release by entering into a
new agreement with the union which imposed liability upon T for severance
pay only where T failed to give specified notice to its employees prior to
closing. Held, T may not increase its cost basis of the assets
purchased by reason of its contingent liability for severance pay. 
United States Tax Court
Warren Brekke, Transferee
Petitioner,
v.
Commissioner of Internal Revenue,
Respondent

Docket No. 79302
Date of Decision: August 2, 1963
Judge:  Train.
Parallel Citations: 40 T.C. 789