MURPHY v. COMMISSIONER

Docket No. 87033.

21 T.C.M. 1161 (1962)

T.C. Memo. 1962-219

Paul F. Murphy and Anna Katherine Murphy v. Commissioner.

United States Tax Court.

Filed September 14, 1962.


Attorney(s) appearing for the Case

Charles P. Duffy, Esq., William T. Schantz, Esq., and Prescott W. Cookingham, Esq., for the petitioners. Donald G. Daiker, Esq., and Aaron S. Resnik, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

FAY, Judge:

The respondent determined deficiencies in the petitioners' income taxes, as follows:

  Year                    Amount

  1952 ...............  $8,670.52
  1953 ...............   6,025.78
  1954 ...............   6,385.38

The only issue for decision is whether payments to petitioner Paul F. Murphy by a corporation pursuant to a promissory note constitute dividends to him.

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