ESTATE OF BROWN v. COMMISSIONER

Docket No. 2124-73.

33 T.C.M. 873 (1974)

T.C. Memo. 1974-201

Estate of Harry L. Brown, Thomas Grainger, Administrator, W.W.A. v. Commissioner.

United States Tax Court.

Filed July 31, 1974.


Attorney(s) appearing for the Case

Kenneth R. Hughes, 1816 First Nat'l Bank Bldg., Cincinnati, Ohio, for the petitioner. Rudolf L. Jansen, for the respondent.


Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $26,581.02 in petitioner's Federal income tax for the period December 29, 1966 through March 31, 1967. The sole issue for decision is whether the petitioner realized dividend income through the payment of its debt by a corporation of which petitioner was the principal shareholder.

Findings of Fact

Some of the facts have been stipulated and are...

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