MATTHIESSEN v. COMMISSIONER

Docket No. 24666.

16 T.C. 781 (1951)

ERARD A. MATTHIESSEN AND ELIZABETH C. MATTHIESSEN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 13, 1951.


Attorney(s) appearing for the Case

Donald M. Dunn, Esq., for the petitioners.

William A. Schmitt, Esq., for the respondent.


The respondent determined a deficiency of $34,521.83 in the petitioners' income tax liability for the year 1941.

The sole issue is whether advances made by petitioners to a corporation controlled by them were loans or investments.

FINDINGS OF FACT.

Such of the facts as were stipulated are so found, and in so far as they appear pertinent to the issues, are incorporated in the other facts below.

Petitioners Erard A. and Elizabeth C. Matthiessen...

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