GREENTHAL v. COMMISSIONER

Docket No. 83944.

21 T.C.M. 659 (1962)

T.C. Memo. 1962-126

Stanley and Florence Greenthal v. Commissioner.

United States Tax Court.

Filed May 25, 1962.


Attorney(s) appearing for the Case

Allan A. Bakst, Esq., 152 W. 42nd St., New York, N. Y., for the petitioners. Ronald S. Schacht, Esq., for the respondent


Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in petitioners' income tax for the calendar year 1954 in the amount of $11,494.60 and additions to the tax under sections 294 (d)(1)(A) and 294(d)(2) of the Internal Revenue Code of 1939 in the respective amounts of $1,119.92 and $726.43.

The issues for decision are:

(1) Whether petitioners during the year 1954 received a dividend from a wholly owned...

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