Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $18,041 in petitioners' 1979 Federal income tax. The issues are: (1) whether a distribution by petitioner James A. Parfrey's solely owned corporation was a dividend or a loan; (2) whether interest earned on the proceeds of that distribution is taxable to petitioners or to their children.
Findings of Fact
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