SCHWARTZ v. COMMISSIONER

Docket No. 9278-76.

40 T.C.M. 497 (1980)

T.C. Memo. 1980-212

Michael J. and Morna R. Schwartz v. Commissioner.

United States Tax Court.

Filed June 23, 1980.


Attorney(s) appearing for the Case

Benjamin Alpert, 271 Madison Ave., New York, New York, Myles J. Sachs, and Gerald W. Keil, for the petitioners. Michael A. Mayhall, for the respondent.


Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined a deficiency of $23,811.46 in petitioners' 1966 Federal income taxes. After petitioners' concessions, the sole issue is whether payments made by two corporations partially discharging Federal income tax liabilities of Morna R. Schwartz for prior years are taxable to her as constructive dividends.

Findings of Fact

Some of the facts were stipulated and are found accordingly...

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