P. M. FINANCE CORPORATION v. COMMISSIONER

Docket Nos. 77725, 84356.

20 T.C.M. 537 (1961)

T.C. Memo. 1961-108

P. M. Finance Corporation v. Commissioner.

United States Tax Court.

Filed April 14, 1961.


Attorney(s) appearing for the Case

Robert Ash, Esq., 1921 Eye St., N. W., Washington, D. C., and Carl F. Bauersfeld, Esq., for the petitioner. David E. Crabtree, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

Respondent determined deficiencies in income tax of petitioner for the taxable years ending May 31, 1955, May 31, 1956, and May 31, 1957, in the respective amounts of $3,849.27, $4,047.25 and $6,765.79.

The sole issue for decision is whether amounts paid by petitioner to its sole stockholder and his wife during the taxable years constitute deductible interest on an indebtedness or nondeductible dividend distributions...

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