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ANASTASATO v. COMMISSIONER

Docket No. 14631-81.

52 T.C.M. 293 (1986)

T.C. Memo. 1986-400

Pano Anastasato and Janice Anastasato v. Commissioner.

United States Tax Court.

Filed August 26, 1986.

Attorney(s) appearing for the Case

Alan H. Levine, for the petitioners. Jack H. Klinghoffer, for the respondent.

Supplemental Memorandum Opinion

KÖNER, Judge:

In Anastasato v. Commissioner [Dec. 41,925(M)], T.C. Memo. 1985-101, we sustained the Commissioner's determination that override payments were made by KLM Royal Dutch Airlines ("KLM") during the years 1974 through 1976 to Panmarc, a corporation wholly-owned by petitioner Pano Anastasato ("Pano"), and through it to Pano.

We concluded that — since...

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