GILBERT v. COMMISSIONER

Docket No. 8774-78.

74 T.C. 60 (1980)

GILBERT L. GILBERT AND FLOSSIE GILBERT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 15, 1980.


Attorney(s) appearing for the Case

Arnold R. Petralia, for the petitioners.

William J. Neild, for the respondent.


TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' income tax for the year 1975 in the amount of $7,483. The issue for decision is whether a transfer of $20,000 by Jetrol, Inc., to G&H Realty Corp. constituted a constructive dividend to petitioner Gilbert L. Gilbert, the common shareholder of each corporation.

FINDINGS OF FACT

Some of the facts have been stipulated. The stipulation of facts and exhibits are incorporated...

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