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DAVIDSON CHEVROLET CO. v. COMMISSIONER

Docket No. 2619-78.

39 T.C.M. 299 (1979)

T.C. Memo. 1979-414

Davidson Chevrolet Company and Monte Zinn Chevrolet Co. v. Commissioner.

United States Tax Court.

Filed October 2, 1979.

Attorney(s) appearing for the Case

Robert E. Harley, 203 First Nat'l Bank Bldg., Springfield, Ohio, for the petitioners. Mary Helen Weber, for the respondent.

Memorandum Opinion

DAWSON, Judge:

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

     Petitioner               Year  Deficiency

Davidson Chevrolet Co. ...... 1975    $6,750
Monte Zinn Chevrolet Co. .... 1975     6,387

The only issue presented for decision is whether the petitioners were members of a controlled group of corporations within the meaning of section 1563(a)(2)

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