ALLEN v. COMMISSIONER

Docket No. 1427-80.

49 T.C.M. 677 (1985)

T.C. Memo. 1985-54

Irving Allen and Juanita Allen v. Commissioner.

United States Tax Court.

Filed February 4, 1985.


Attorney(s) appearing for the Case

Joel R. Weinstein and Bert B. Rand, for the petitioners. Cruz Saavedra, for the respondent.


Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income taxes of $257,047 for 1973 and $43,822 for 1974. After concessions, the issues for decision are: (1) Whether certain transfers of funds made during 1973 by two companies, both wholly owned by the petitioners, to another company, wholly owned by the petitioners and their children...

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