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ZAGER v. COMMISSIONER

Docket No. 11051-78.

72 T.C. 1009 (1979)

MAX ZAGER AND GOLDIE R. ZAGER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 5, 1979.

Attorney(s) appearing for the Case

William L. Tankersley III, for the petitioners.

Edwina L. Link, for the respondent.

OPINION

RAUM, Judge:

The Commissioner determined deficiencies in income tax against petitioners, husband and wife, in the amounts of $6,179.75 and $6,627.18, for the calendar years 1975 and 1976, respectively. After concessions by petitioners as to certain adjustments made by the Commissioner, there remains in controversy only whether petitioners realized taxable income in respect of their interest-free use of funds borrowed from a corporation in...

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