PETERSON v. COMMISSIONER

Docket No. 95108.

23 T.C.M. 63 (1964)

T.C. Memo. 1964-15

Robert N. Peterson and Martha T. Peterson v. Commissioner.

United States Tax Court.

Filed January 28, 1964.


Attorney(s) appearing for the Case

Stafford R. Grady, for the petitioners. Marion Malone, for the respondent.


Memorandum Findings of Fact and Opinion

HARRON, Judge:

The respondent determined a deficiency in income tax for the year 1958 in the amount of $142,044.57. In 1958, Peterson Manufacturing Company acquired 128 shares of its common stock for $192,000, which have been held since then as treasury shares. The issue presents the questions whether Robert M. Peterson, a stockholder, is chargeable with a constructive distribution...

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