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SWAIN v. COMMISSIONER

Docket No. 2157-78.

43 T.C.M. 121 (1981)

T.C. Memo. 1981-716

Elbert D. and Mae M. Swain v. Commissioner.

United States Tax Court.

Filed December 17, 1981.

Attorney(s) appearing for the Case

John Q. Beard, 414 Fayetteville St. Mall, Raleigh, N.C., and Barbara Mills Larkin, for the petitioners. Frank D. Armstrong, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

  Year                    Deficiency

  1972 ...............    $ 44,209.09
  1973 ...............     108,232.02

Concessions having been made by both parties, the only question remaining for our consideration is whether transfers of funds from certain corporations controlled by petitioners to...

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