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HARDY v. COMMISSIONER

Docket No. 11403-79.

43 T.C.M. 1210 (1982)

T.C. Memo. 1982-225

Leonard W. Hardy and Geraldine C. Hardy v. Commissioner.

United States Tax Court.

Filed April 28, 1982.

Attorney(s) appearing for the Case

James Silhasek, 3010 East Camelback Rd., Phoenix, Ariz., for the petitioners. David W. Otto, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined a deficiency of $394,029.74 in the petitioners' Federal income tax for 1974 and an addition to tax of $19,701.49 under section 6653(a) of the Internal Revenue Code of 1954.1 After concessions by both parties, the issues for decision are: (1) Whether cash withdrawn by the petitioners for their own use from a corporation controlled by them constituted...

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