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H. R. SPINNER CORPORATION v. COMMISSIONER

Docket No. 483-69.

29 T.C.M. 462 (1970)

T.C. Memo. 1970-99

H. R. Spinner Corporation v. Commissioner.

United States Tax Court.

Filed April 28, 1970.

Attorney(s) appearing for the Case

C. W. Halverson and Donald H. Bond, 415 North Third St., P. O. Box 526, Yakima, Wash., for the petitioner. Gary C. Randall, for the respondent.

Memorandum Opinion

DAWSON, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes for the fiscal years ended March 31, 1964, and March 31, 1965, in the amounts of $32,608.71 and $44,368.33, respectively. The only issues for decision are (1) whether certain notes issued by petitioner to its stockholders constitute a second class of stock within the meaning of section 1371(a), Internal Revenue Code of 1954,1

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