OPINION
KASHIWA, Judge:
The above-entitled claims are consolidated suits for the refund of federal income taxes for calendar year 1969. An assessment was made by the Government on a "distribution and loan-back" transaction made on or about April 12, 1969, between McKelvy Furniture, Inc. and its shareholders, Robert H. and Maxine McKelvy and R. Hugh and Tula E. McKelvy, involving the amounts of $5,136.17 and $17,851.74, respectively...
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