FALKOFF v. COMMISSIONER

Docket No. 6709-74.

36 T.C.M. 417 (1977)

T.C. Memo. 1977-93

Milton Falkoff and Jeannette L. Falkaoff v. Commissioner.

United States Tax Court.

Filed March 31, 1977.


Attorney(s) appearing for the Case

Byron S. Miller, Alan L. Reinstein and Geoffrey F. Grossman, 33 N. LaSalle St., Chicago, Ill., for the petitioners. Seymour I. Sherman, for the respondent.


Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1969 in the amount of $164, 425.52.

The remaining issue for decision is whether a series of transactions, whereby the indebtedness of the partnership in which the petitioner had an interest to the First National Bank of Chicago was repaid, resulted in a distribution of earnings and profits by Henry Crown...

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