ZOHOURY v. COMMISSIONER

Docket Nos. 11566-80, 23910-81.

46 T.C.M. 1521 (1983)

T.C. Memo. 1983-597

Badi Zohoury and Wilma J. Zohoury v. Commissioner.

United States Tax Court.

Filed September 26, 1983.


Attorney(s) appearing for the Case

Fred A. Foley, 755 West Big Beaver Rd., Troy, Mich., for the petitioners. F. Michael Kovach, Jr., for the respondent.


Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined deficiencies in petitioner's Federal income tax as follows:

  Tax Year              Deficiency

  1977 ................ $27,316.00
  1978 ................  13,781.71

After concessions by the petitioners, the issues are: (1) whether funds transferred to petitioners from Zabih Zohoury, Irene Warren and F. Momtoz were bona fide loans; (2) if so, whether...

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