MILLER v. COMMISSIONER

Docket No. 1181-78.

41 T.C.M. 139 (1980)

T.C. Memo. 1980-445

Theodore C. Miller and Vivian Miller v. Commissioner.

United States Tax Court.

Filed October 6, 1980.


Attorney(s) appearing for the Case

James R. Addison, 200 St. Clair Bldg., Marietta, Ohio 45750, for the petitioners. Donald W. Mosser, for the respondent.


Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined deficiencies in Federal individual income tax against petitioners for 1971, 1972 and 1973 in the amounts of $4,053.39, $6,369.62, and $18,448.14, respectively.

After respondent's concession of one issue, the issue for decision is whether net transfers to petitioners from their wholly-owned corporation were loans (not taxable to petitioners in the years before the Court)...

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