STEELMASTERS, INC. v. COMMISSIONER

Docket No. 836-74.

35 T.C.M. 1460 (1976)

T.C. Memo. 1976-324

Steelmasters, Inc. v. Commissioner.

United States Tax Court.

Filed October 21, 1976.


Attorney(s) appearing for the Case

Patrick J. Murphy, for the petitioner, 425 Park Ave., New York, N.Y.E. Noel Harwerth, for the respondent.


Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined the following deficiencies in petitioner's Federal income tax:

       FYE                   Deficiency

     2/28/69 ...............  $15,901
     2/28/70 ...............   15,982

We are to decide whether during the years in issue petitioner was availed of for the purpose of avoiding income tax with respect to its shareholders by permitting its earnings and...

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