MILLER REALTY COMPANY v. COMMISSIONER

Docket No. 4222-74.

36 T.C.M. 1821 (1977)

T.C. Memo. 1977-440

Miller Realty Company v. Commissioner.

United States Tax Court.

Filed December 29, 1977.


Attorney(s) appearing for the Case

John J. O'Toole, Edwin Fradkin, Bruce E. Goldman, and William D. Hecht, for the petitioner.

Gerald J. O'Toole, for the respondent.


Memorandum Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioner's Federal income tax in the amounts of $18,408.93 and $422.29 for its fiscal years ended November 30, 1968 and 1969, respectively.

The issues for decision are:

(1) Whether a bona fide indebtedness was created by advances of funds by petitioner to another corporation, all of the stock of which was owned by members of the same family that owned petitioner's stock...

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