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WILKOF v. COMMISSIONER

Docket No. 5750-77.

37 T.C.M. 1851 (1978)

T.C. Memo. 1978-496

Edward Wilkof and Ruth Wilkof, Ervin Wilkof and Marie Wilkof v. Commissioner.

United States Tax Court.

Filed December 13, 1978.

Attorney(s) appearing for the Case

Zolman Cavitch and Harvey L. Frutkin, 1401 East Ohio Bldg., Cleveland, Ohio, for the petitioners. Robert N. Armen, Jr. and Buckley D. Sowards, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

     Petitioner        Year    Deficiency

  Edward Wilkof and
   Ruth Wilkof .....   1973     $112,910
  Ervin Wilkof and
   Marie Wilkof ....   1973      115.198

The issues for decision are:

1. Whether intercorporate transfers of $420,000 from Wilkof Structural Steel Corporation...

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