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HUFNAGLE v. COMMISSIONER

Docket No. 15700-84.

51 T.C.M. 694 (1986)

T.C. Memo. 1986-119

Paul C. Hufnagle and G. Phyllis Hufnagle v. Commissioner.

United States Tax Court.

Filed March 24, 1986.

Attorney(s) appearing for the Case

Paul C. Hufnagle, pro se, Bloomington, Minn. Mark Pridgeon, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

With respect to petitioners' 1980 Federal income tax, respondent determined a deficiency of $5,257 and an addition to tax of $263 under section 6653(a).1 After concessions, the issues are: (1) whether petitioners must include in gross income a management fee in the amount of $12,000; (2) whether petitioners must include in gross income as a constructive dividend the amount of...

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