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NOBLE v. COMMISSIONER

Docket No. 2054-63.

24 T.C.M. 442 (1965)

T.C. Memo. 1965-84

Cornelius C. Noble and Pansy H. Noble v. Commissioner.

United States Tax Court.

Filed April 7, 1965.

Attorney(s) appearing for the Case

Denslow B. Green, for the petitioners. Roger A. Pott and James Booher, for the respondent.

Memorandum Findings of Fact and Opinion

ATKINS, Judge:

The respondent determined deficiencies in income tax for the taxable years 1958, 1959, and 1960 in the respective amounts of $2,394.59, $3,716.74, and $4,395.27.

The sole issue for decision is whether payments of certain personal expenses by a corporation on behalf of its sole stockholders constituted repayments of their loan to the corporation or constructive dividends to them.

Findings...

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