Memorandum Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $5,319.00 in petitioners' income tax for the taxable year 1984. After concessions, the sole issue for decision is whether $1,610.00 of corporate expenditures in respect of a corporate automobile used by petitioners represents the repayment of a loan or a constructive dividend.
All of the facts have been stipulated, and the stipulation of facts and attached exhibits are incorporated...
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