CONGLETON v. COMMISSIONER

Docket No. 11953-77.

38 T.C.M. 584 (1979)

T.C. Memo. 1979-130

Lucien H. Congleton and Jane Congleton v. Commissioner.

United States Tax Court.

Filed April 5, 1979.


Attorney(s) appearing for the Case

Charles R. Hembree and Philip E. Wilson, Central Bank, Lexington, Ky., for the petitioners. Eugene P. Bogner for the respondent.


Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined deficiencies in income tax paid by petitioners in the amount of $30,224.94 for the taxable year 1972 and $5,002.98 for the taxable year 1974. The issue which remains for decision is whether petitioner constructively received salaries due but not paid to him for the taxable years 1972 and 1974 until after the close of such years. Petitioner alternatively contends that if it is held...

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