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JONES v. COMMISSIONER

Docket No. 384-73.

34 T.C.M. 488 (1975)

T.C. Memo. 1975-101

Robert Trent Jones and Ione Davis Jones v. Commissioner.

United States Tax Court.

Filed April 14, 1975.

Attorney(s) appearing for the Case

Martin D. Cohen, 744 Broad St., Newark, N.J., for the petitioners. William M. Gross, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

The respondent determined a deficiency of $12,874.25 in the federal income taxes of the petitioners for the calendar year 1968. Certain issues not having been raised in the petition, the sole issue for decision is whether petitioner Robert Trent Jones constructively received a dividend in the amount of $22,075 from International Planners Limited in 1968.

Findings of Fact

Some of the...

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