KIRKPATRICK v. COMMISSIONER

Docket No. 3805-76.

36 T.C.M. 1122 (1977)

T.C. Memo. 1977-281

Donald O. and Carolyn Kirkpatrick v. Commissioner.

United States Tax Court.

Filed August 22, 1977.


Attorney(s) appearing for the Case

William H. Sutton, Byron M. Eiseman, Jr., and Lewis H. Mathis, First Nat'l Bldg., Little Rock, Ark., for the petitioners. Suzanne B. O'Neill, for the respondent.


Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined deficiences in the Federal income taxes of petitioners for the taxable years 1972 and 1973 in the amounts of $27,363 and $31,204.23, respectively.

The only issue for decision is whether all of the taxable income of Quality Poultry and Egg Co., Inc. for its fiscal years ended June 30, 1972, and 1973, respectively, is attributable to petitioners and should be included in their...

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