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O'CONNOR v. COMMISSIONER

Docket No. 5734-83.

51 T.C.M. 138 (1985)

T.C. Memo. 1985-616

George O'Connor and Karla O'Connor v. Commissioner.

United States Tax Court.

Filed December 17, 1985.

Attorney(s) appearing for the Case

Andrew C. Barnard and George S. Barnard, for the petitioners. Vera E. Gilford, for the respondent.

Meorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined a deficiency in petitioners' income tax for 1975 in the amount of $26,458 and addition to tax under section 6653(a)1 in the amount of $1,323.

The issues for decision are (1) whether George O'Connor received a constructive dividend in 1975 in the amount of $47,547 from Brackin-Ward Ford, Inc., his wholly-owned corporation, and (2) if the resolution...

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