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HUNTER v. COMMISSIONER

Docket No. 11519-78.

44 T.C.M. 385 (1982)

T.C. Memo. 1982-381

John C. Hunter v. Commissioner.

United States Tax Court.

Filed July 7, 1982.

Attorney(s) appearing for the Case

Milton D. Price, Jr., 500 Degree of Honor Bldg., St. Paul, Minn., for the petitioner. James C. Lanning, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

By notice of deficiency dated July 14, 1978, respondent determined a deficiency in the amount of $115,726 in petitioner's Federal income tax for the taxable year 1971. The issues for decision are: (1) whether certain guaranties by petitioner in substance constituted contributions to the capital of a corporation rather than bona fide debt obligations...

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