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KOUFMAN v. COMMISSIONER

Docket No. 8770-73.

69 T.C. 473 (1977)

MANUEL M. KOUFMAN AND CHARLOTTE KOUFMAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 13, 1977.

Attorney(s) appearing for the Case

David R. Andelman, for the petitioners.

Amy Robertson Goldson, for the respondent.

OPINION

SIMPSON, Judge:

On October 28, 1976, this Court filed its Memorandum Findings of Fact and Opinion in this case (T.C. Memo. 1976-330). Therein, we found that, inter alia, a $16,752 corporate distribution in 1968 by Koufman Construction Co. of Boston to the petitioners was a dividend under section 301 of the Internal Revenue Code of 1954.1 However, we withheld entry of our decision...

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